2026 (3) TMI 1652 - AT - Customs

Customs classification of EPS-ECU upheld as motor vehicle steering part, not Chapter 90 apparatus, on identical goods reasoning.

Imported Electronic Power Steering- Electronic Control Unit (EPS-ECU) was held to be classifiable as a part of the motor vehicle power steering system ... Customs tariff classification - Classification of Electronic Power Steering ECU - Precedential disciplineCustoms tariff classification - Electronic Power Steering ECU - Binding coordinate bench decision - Classification of the imported EPS-ECU under CTI 8708 94 00 or CTI 9032 90 00 stood concluded against the appellant by the Tribunal's earlier decision in the appellant's own case. - HELD THAT: - The Tribunal found that the goods in the present appeals were identical to the EPS-ECU considered in its earlier final order concerning the same appellant. It examined the later Chennai Bench decision in Hyundai Motors and noted that, although that order treated classification of each ECU as dependent on its own merits, it had distinguished Continental Automotive on facts and had not considered the earlier order passed in the appellant's own case. Since the present goods were the same as those covered by the earlier order, and that order had not been stayed despite challenge before the Supreme Court, the Tribunal held that the earlier decision continued to govern the classification dispute. On that basis, EPS-ECU remained classifiable under CTI 8708 94 00 and not under CTI 9032 90 00. [Paras 6, 8, 9, 10]The classification adopted in the impugned order under CTI 8708 94 00 was upheld and all the appeals were dismissed.Final Conclusion: Following its earlier order in the appellant's own case on identical goods, the Tribunal held that EPS-ECU was correctly classifiable under CTI 8708 94 00. The impugned appellate order was upheld and all 196 appeals were dismissed. Issues: (i) Whether the imported Electronic Power Steering- Electronic Control Unit (EPS-ECU) was classifiable under Customs Tariff Item 8708 94 00 as a part of motor vehicle power steering system or under Customs Tariff Item 9032 90 00 as claimed by the appellant.Analysis: The dispute was identical to the earlier appeals decided in the appellant's own case. The Tribunal noted that the earlier final order had already held EPS-ECU to be a part of the power steering system and not an instrument or apparatus falling under Chapter 90. It further noted that subsequent Chennai Bench decisions on different ECUs did not alter the position because classification depends on the specific goods and the present ECU was identical to the one previously considered. In these circumstances, the earlier decision continued to govern the issue.Conclusion: EPS-ECU was correctly classifiable under CTI 8708 94 00 and not under CTI 9032 90 00. The finding was against the appellant and in favour of the Revenue.