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CESTAT examined the classification of imported One Time Seals with RFID, determining whether they fall under CTI 8523 59 10, as claimed by the appellant, or CTI 8309 90 30. Applying the essential character test, the Tribunal held that despite RFID functionality, the goods are fundamentally security seals rather than data-storage devices. The Revenue's contention that the seals' primary character is that of "seals" was accepted. It was further held that show cause notices under Section 28(1) validly raised reclassification within limitation. The impugned order reclassifying the goods under CTI 8309 90 30 was upheld and the appeal dismissed.
CESTAT examined the classification of imported One Time Seals with RFID, determining whether they fall under CTI 8523 59 10, as claimed by the appellant, or CTI 8309 90 30. Applying the essential character test, the Tribunal held that despite RFID functionality, the goods are fundamentally security seals rather than data-storage devices. The Revenue's contention that the seals' primary character is that of "seals" was accepted. It was further held that show cause notices under Section 28(1) validly raised reclassification within limitation. The impugned order reclassifying the goods under CTI 8309 90 30 was upheld and the appeal dismissed.
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