TaxTMI 
TaxTMI 
TaxTMI 
2025 (12) TMI 688
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....ns are as given below :- Statement of relevant facts having a bearing on the Question (s) raised 1.2 M/s ATL Battery Technology (India) Private Limited (hereinafter referred to as the "Applicant"), a Company having its Registered Office cum Principal Place of Business at Plot No. 197, Sector-4, Phase-II, HSIIDC Industrial Area Growth Centre, Bawal, Rewari, Haryana-123501, is setting up another manufacturing unit, a state-of-the-art Lithium-Ion Cell manufacturing facility at EP-1, Sector-20, IMT Sohna, Dist .- Nuh, Haryana (hereinafter referred to as "Manufacturing Units"). The Applicant is an ultimate subsidiary of TDK Corporation, an entity listed in the recognized stock exchange of Tokyo, Japan. ATL is the world's leading producer and innovator of lithium-ion batteries. ATL is a subsidiary of the TDK Corporation, a Japanese multinational electronics corporation, known worldwide for their high-tech, high-volume prowess in developing, producing, and packaging high-quality rechargeable lithium-ion battery cells and packs. 1.3 ATL is the world's leading producer and innovator of high-performance Lithium-ion Cell production for various consumer electronics & telecommu....
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.... the 'Notification') wherein at Sr. No. 523A of the Notification, exemption is provided to parts, sub-parts, inputs or raw material for use in manufacture of Lithium-ion cells falling under CTH 8507 6000, subject to certain conditions. It is asserted that the Applicant believes that they are duly covered under the said Notification given that the same are being used in the manufacturing of the final product viz., Lithium-ion cells. Towards this, the Manufacturing Process Flow Chart may be perused. 1.10 In the light of the above facts, the Applicant desires to obtain an Advance Ruling under Section 28H of the Customs Act, 1962 (hereinafter referred to as the 'Act') to validate the recommended Classification of the imported goods as mentioned in Appendix- I. 1.11 Further, the Advance Ruling is also being sought with respect to the eligibility of concessional benefit of the Basic Customs Duty under Sr. No. 523A of Notification No. 50/2017-Cus dated 30.06.2017 available on importing the parts, sub-parts, inputs or raw materials as mentioned in Appendix-I for the manufacture of Lithium-ion cells .. Statement of Applicant's Interpretation of law 1.12 The A....
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....of the Customs Tariff Act, 1975 as mentioned in Appendix-I? 1.18 If the subject parts, sub-parts, inputs or raw materials/Products are not classifiable under the recommended Custom Tariff Headings as adopted by the Applicant as mentioned in Appendix- I, then what should be the appropriate classification/CTH for the parts, sub- parts, inputs or raw materials/Products to be imported by the Applicant given the composition and end use of the subject parts, sub-parts, inputs or raw materials/Products? 1.19 Given that parts, sub-parts, inputs or raw materials/Products are used in the manufacture of the final product viz., Lithium-ion cells (classified by the Applicant under Custom Tariff Headings 8507 6000 of the Import Tariff of the Customs Tariff Act, 1975), whether the Applicant is eligible to avail the benefit(s) of the concessional rate of Basic Customs Duty under Sr. No. 523A of Notification No. 50/2017-Cus dated 30.06.2017 since the said Entry covers "Parts, sub-parts, inputs or raw material for use in manufacture of Lithium ion cells falling under tariff item 8507 60 00" of the Import Tariff of the Customs Tariff Act, 1975 Details of the goods to be imported (as raw mate....
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....o determine whether a product is a part of a machinery, it can be said that Cathode being an electrode in the Lithium-ion cell is a part of Lithium-ion cell. Since cathode is a part of Lithium-ion cell, the classification shall be governed by Note 2 of Section XVI. On perusal of the headings under Chapter 84/85, it is evident that the product is not covered by any of the specific headings. Since the cathode is not classifiable under any of the headings of Chapter 84 and 85 in accordance with Note 2(a) to Section XVI, therefore, the classification of the product, being a part of Lithium-ion cell, will be governed by the provisions of Note 2(b) to Section XVI. Accordingly, as per Section Note 2(b), it merits classification under the heading under which the Lithium-ion cell is classified i.e. CTH 8507 (discussed in detail under the heading "Classification of Treated Separator-II"). Reference is drawn to the HSN Explanatory Notes to CTH 8507 which, inter-alia, provides that subject to the general provisions regarding the classification of parts (see the General Explanatory Note to Section XVI), the heading also covers parts of accumulators. Here, it is pertinent to note that the ....
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.... electrons to the external circuit and is oxidized during the electrochemical reaction. Lithium-ion cells are classifiable under CTH 8507 which covers "Electric accumulators, including separators therefor, whether or not rectangular (including square)" (discussed in detail under the heading "Classification of Treated Separator-II"). On a perusal of the HSN Explanatory Notes to CTH 8507, it is clear that electrodes (anode/cathode) are part of accumulator and the cell is incomplete without the same and will not be able to function unless the electrodes (anode/cathode) are present. The relevant portion of the HSN Explanatory to CTH 8507 has been reproduced below for ease of reference: " .... Accumulators consist essentially of a container holding the electrolyte in which are immersed two electrodes fitted with terminals for connection to an external circuit. In many cases the container may be subdivided, each subdivision (cell) being an accumulator in itself; these cells are usually connected together in series to produce a higher voltage. ... The main types of accumulators are: (2) Alkaline accumulators, in which the electrolyte is usually potassium, or lithiu....
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....or without metal, of a kind used for electrical purposes.". CTH 8545 covers all articles of graphite or other carbon which are recognizable by their shape, dimensions or otherwise, as being for electrical purposes, whether or not they contain metal. The relevant portion of the HSN explanatory notes has been extracted below for ease of reference :- "This heading covers all articles of graphite or other carbon which are recognizable by their shape, dimensions or otherwise, as being for electrical purposes, whether or not they contain metal. In general, these articles are obtained by the extrusion or by the moulding (usually under pressure) and heat-treatment of a composition which, in addition to its basic constituent (natural carbon, carbon black, gas carbon, coke, natural or artificial graphite, etc.) and the necessary binders (pitch, tar, etc.), may also contain other substances such as metallic powders ... " From a combined reading of heading of 8545 and the above extract of HSN Explanatory Notes, it can be seen that an electrode made of graphite (used for electrical purpose) are cover se) are covered under the said CTH. Since the predominant constituent element in th....
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.... attained characteristics of a specific part, the benefit of Notification No. 181/87-Cus. cannot be denied merely because such part was subjected to operation of cutting to required length, drilling of holes and chrome plating before fitting to machinery. It was also noted that the importer has clearly explained that cutting and putting holes is for fitting the item. The 'nose bar' has a specific perforation for fitment and the profile has been so designed to fit inside the nose bar holder. In the case of EPC Irrigation Ltd. vs. Commissioner of Cus. & C. Ex., Aurangabad, 2002 (139) E.L.T. 84 (Tri .- Mumbai) [Affirmed in 2010 (254) E.L.T. A99 (Supreme Court)], the Hon'ble Tribunal held that pipes and fittings forming part of sprinkler and irrigation system are classifiable under Heading 8424 as all the pipes and tubes in question are not used merely to connect individual components or separate machines but are themselves essential for the functioning of the system as a whole and are therefore in the nature of parts of the system. It was also noted that the pipes and tubes are of different size, specific diameter, cut to size and assembled in the site of the system so ....
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....o act as a physical barrier between the anode and the cathode to prevent electrical short circuits, while facilitating ion transportation which is needed to complete the circuit during the passage of current in the Lithium-ion cell. Based on the above understanding, the contending headings for classification of large films of separator are as follows:- - CTH 8507 which covers "Electric accumulators, including separators therefor, whether or not rectangular (including Square)" - CTH 3921 which covers "Other plates, sheets, film, foil and strip, of plastics". CTH 8507 covers "Electric accumulators, including separators therefor, whether or not rectangular (including square)" The HSN Explanatory Notes to 8507 explains the functioning of electric accumulators. And the types of electric accumulator. The relevant portion of the HSN Explanatory to CTH 8507 has been reproduced below for ease reference: "Electric accumulators (storage batteries or secondary batteries) are characterized by the fact that the and supply it when required. A direct current is passed through the accumulator producing certain changes (charging); when the terminals of the accumulator a....
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....008 (224) E.L.T. 512 (S.C.), wherein the court draws a distinction between parts and accessories based on their essentiality to the functioning of the main product. For ease of reference, the relevant portion of the judgment is extracted as under: "18. After considering in detail, the difference between the 'accessories 'and 'parts', this Court in the case of Pragati Silicon (supra) came to conclusion that 'accessory' is something supplementary or subordinate in nature and need to be essential for the actual functioning of the product 19. Chapter 9401 covers all types of seats der seat only the seats of a car and a seat is complete even without the rail assembly from seat, adjuster/asse and rear back lock assembly. They are not essential parts of the seat. Chapter heading 9401 covers only the parts of seats and not accessories to the seats. A 'part 'is an essential component of the whole without which the whole cannot function" Reliance is placed on the case of CTO, Anti Evasion, Circle III, Jaipur vs. Prasoon Enterprises, 2019 (23) GSTL 441(SC) Wherein it has been held that a thing is a part of the other if the other is incomplete withou....
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....SN Explanatory Notes to Section XVI is extracted for ready reference, "(II) PARTS (Section Note 2) In general, parts which are suitable for use solely or principally with particular machines or apparatus (including those of heading 84.79 or heading 85.43 ), or with a group of machines or apparatus falling in the same heading, are classified in the same heading as those machines or apparatus ... The above rules do not apply to parts which in themselves constitute an article covered by a heading of this Section (other than headings 84.87 and 85 .48); these are in all cases classified in their own appropriate heading even if specially designed to work as part of a specific machine ... ... Machinery parts remain classified in this Section whether or not finished ready for use. However, rough forgings of iron or steel are classified in heading 72.07." Considering the above extracted portion of HSN Explanatory Notes, it is evident that parts which are goods classifiable under any of the headings of Chapters 84 and 85 should be classified in the headings of the said chapters (excluding headings 8409, 8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 85....
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.....L.T. 1 .Chennai), wherein the Hon'ble Tribunal held that fibre glass in running length in jumbo rolls merits classification as battery separators under CTH 8507 with attendant benefit. length in jumbo rolls merits classification as battery separators under CTH 8507 with attendant benefit. It was noted that the impugned goods had to be cut into exact specifications for them to be used in battery separators. The Hon'ble Tribunal rejected the order passed by the Commissioner (Appeals) wherein it was wrongly held that fibre glass the commissioner Appeals) in running length were raw material required to manufacture battery separators. In the present case, large film of the separator will be imported which will undergo the process of slitting such that the smaller films can be used as separator in the manufacture of Lithium-ion cells. Basis the forgoing discussion and judicia pronouncements, it is pertinent to note that the product fulfils the criteria as mentioned in the HSN Explanatory Note to CTH 8507. Therefore, the product is classifiable as part of accumulator under tariff entry 8507 90 10 which reads as "Electric accumulators, including separators therefor, whether ....
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....issionerate is as follows:- 2.2 The relevant portion of the Customs Tariff is produced below: 8507 LECTRIC ACCUMULATORS, INCLUDING SEPARATORS THERE FOR, WHETHER OR NOT RECTANGULAR (INCLUDING SQUARE) 850790- Parts: 85079010 Accumulator cases made of hard rubber and separators 25070000 Other 85079090 Other 2.3. Relevant portion of the Notification No. 50/2017-Customs dated 30.06.2017 is re- produced below: S. No. C Chapter of heading of subheading or Description of goods Standard rate Integrated Goods and Service tax Condition no. 523A Parts, sub-parts, inputs or raw material for use in manufacture of Lithium ion cells falling under tariff item 8507 60 00 NIL 9 Condition No Condition 9 If the importer follows the procedure set out in the Customs of Goods at Concessional Rate of Duty) Rules, 2017 2.3.1 Question 1: Whether the Applicant has rightly classified the goods to be imported which are in Headings of the Import Tariff of the Customs Tariff Act, 1975 as mentioned in Appendix-17 2.3.2 Question 2: If the subject parts, sub-parts, inputs or raw materials / P....
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....s Duty under Sr. No. 523A of Notification No. 50/2017-Cus dated 30.06.2017 since the said Entry covers "Parts, sub-parts, inputs or raw material for use in manufacture of Lithium ion cells falling under tariff item 8507 60 00" of the Import Tariff of the Customs Tariff Act, 1975 2.4 Reply. The benefit of Sr. No. 523A of the Nifn No. 50/2017-Cus dated 30.06.2017 is extendable for the goods viz "Parts, sub-parts, inputs or raw material for use in manufacture of Lithium ion cells falling under tariff item 8507 60 00" falling under "any chapter" Further, applicant is the manufacture of the lithium ion batteries, therefore, if the Applicant is complying to IGCR, 2017 then the benefit sought of Sr. No. 523A of the Ntfn No. 50/2017- Cus dated 30.06.2017 is appears to be extendable and legal 3. Personal Hearing :- During the course of personal hearing held on 07.08.2025, the representatives reiterated written submissions. Further, the Authorised representatives were also asked to submit safety data sheet, technical literature, flow chart and role of subjected goods in the manufacturing. Also, the Authorised representatives were advised to furnish an excel sheet containing the prod....
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....cant for classifying the goods under CTH 8545 1900 before arriving at the final conclusion. The reasoning for classification under CTH 8545 1900 is being provided in Annexure herewith. 4.6 It is also noted that the Port Commissionerate has approved the eligibility of the Customs Exemption Notification No. 50/2017-Cus. dated 30.06.2017 on the subject products. Annexure - Reasoning for classification of "Anode Coated" under CTH 8545 1900 Anode Coated 85451900 Ingredients: Copper Foil (26%), Graphite (74%) Application: Used for lithium-ion anode material, inserting and extracting lithium ion during charge and discharge HSN Classification Justification (as per Applicant) 4.7 The product, as imported, is in the form of large films which after cutting is used as an anode in the manufacturing of a Lithium-ion cell and it consists of copper foil (26%) and graphite (74%). After importation, the large film(s) will undergo the process of slitting such that the films are slit into films of smaller width. The smaller film will undergo auto winding wherein the anode film will be jelly rolled with the smaller films of cathode, tab and separator in a closed chamber. T....
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....uch parts cannot be classified as per Section Note 2(a) i.e. it is to be applied sequentially. 4.11 Considering the foregoing discussion, the classification of the product will firstly be analysed in terms of headings under Chapter 84 and Chapter 85 by applying Note 2(a) to Section XVI. If the product can be classified under specific heading of Chapter 84/85, then it will not be classified as part of Lithium-ion cell under CTH 8507 under Sub-heading 8507 90 by applying Note 2(b) to Section XVI. 4.12 Based on the above understanding, the contending headings for classification of large films of Anode are as follows: - -CTH 8545 which covers "Carbon electrodes, carbon brushes, lamp carbons, battery carbons and other articles of graphite or other carbon, with or without metal, of a kind used for electrical purposes". -CTH 8507 which covers "Electric accumulators, including separators therefor, whether or not rectangular (including square)" CTH 8545 covers "Carbon electrodes, carbon brushes, lamp carbons, battery carbons and other articles of graphite or other carbon, with or without metal, of a kind used for electrical purposes". CTH 8545 covers all articles ....
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....ell. The product, after importation, undergoes the process of slitting but even after slitting, the smaller films possess the same characteristics as possessed by the large films and therefore the roll is classifiable as part of Lithium-ion cell under CTH 8545. 4.16 Reference is drawn to the case of Exide Industries Ltd. vs. Commissioner of Customs, Chennai, 2007 (212) E.L.T. 496 (Tri .- Chennai) [Maintained in 2011 (274) ELT A48 (Supreme Court)], wherein the Hon'ble Supreme Court held that battery separators in roll form merits classification as parts under CTH 8507. Applying the same analogy in the present case, the Applicant is of the view that the films of anode are classifiable under CTH 8545 by applying Section Note 2(a). In this regard, film has been manufactured with such precision that it can be solely/principally used after slitting with Lithium-ion cells manufactured by the Applicant only. 4.17 Reference is also drawn to the case of Commissioner of Customs, Chennai vs. Lakshmi Machine Works Ltd., 2002 (149) E.L.T. 1102 (Tri .- Chennai), wherein the Hon'ble Tribunal held that Steel Nose Bar designed as a part of textile machinery and understood so in textile....
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....ons and other articles of graphite or other carbon, with or without metal, of a kind used for electrical purposes; Electrodes; Others". 4.21 This Office vide letter F.No. VIII/CAAR/Delhi/ATL Battery/81/2025 dated 17.10.2025 further asked the applicant clarification regarding DRI investigation on classification of goods as it was not clear in additional submission dated 09.09.2025 submitted by applicant. 4.22 In response to the letter F.No. VIII/CAAR/Delhi/ATL Battery/81/2025 dated 17.10.2025, the applicant submitted additional submission vide letter dated 27.10.2025 which is reproduced as under :- 4.23 At the very outset, it is respectfully reiterated and submitted that the investigation conducted by the Directorate of Revenue Intelligence (DRI) in the Applicant's case was not in relation to the classification of goods under the Customs Tariff Act, 1975, but was limited to the verification of payment of Integrated Goods and Services Tax (IGST) leviable on imported goods under Section 3(7) of the Customs Tariff Act, 1975, read with Section 12 of the Customs Act, 1962. 4.24 The DRI's inquiry was therefore confined to the rate of IGST applicable on imports, i.e. de....
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....the earliest. This issues with the approval of the Additional Director General, DRI, HZU. Nature and Scope of the DRI Investigation 4.27 The DRI's correspondence - including Enquiry Letter dated 20.01.2023, Summons dated 02.03.2023, and letters dated 23.05.2023 and 17.05.2024 addressed to the concerned port authorities - clearly demonstrates that the scope of investigation was restricted to the verification of the applicable rate of IGST on certain import consignments and not to any doubt regarding the classification of the goods under the Customs Tariff. 4.28 The reference in the DRI's report to "wrong classification" under Notification No. 01/2017- IGST (Rate) was made only in the context of the rate schedule under that notification. However, it appears that the words "wrong classification" have been read by you in isolation and not in complete context. 4.29 The term "classification" in that context refers to identifying the appropriate serial number and Schedule for the purpose of determining the applicable rate of IGST, and not to the tariff heading of the goods under the Customs Tariff Act, 1975. 4.30 The said notification serves as a rate-deter....
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.... the DRI's inquiry determines rate applicability, whereas the CAAR's jurisdiction concerns classification and exemption under customs law. 4.34 Hence, the DRI's verification of IGST rate for the purpose of Section 3(7) of the Customs Tariff Act, 1975 cannot be regarded as a proceeding involving the same "question" as the one raised before this Hon'ble Authority under Section 28-I(2). No Bar under Section 28-1(2) of the Customs Act, 1962 4.35 The second proviso to Section 28-1(2) of the Customs Act, 1962, bars admission of an application only when the same question of law or fact is pending or has been decided in any proceeding in the applicant's case under the Act. 4.36 Since the DRI's limited verification concerned rate applicability under the IGST rate notification and not tariff classification under the Customs Tariff Act, the issue before the DRI and the issue before this Hon'ble Authority are not identical. There exists no pending proceeding involving the same question of classification or exemption. The present Applications are therefore maintainable, and may be adjudicated on merits in accordance with law. Prayer In light of t....
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....e for accumulators, placed between anode and cathode to prevent short-circuit while permitting ionic conduction. They separate the positive and negative pole pieces to transmit lithium ions. (iv) LC breaker - It is an electrical protective device integrated in the cell line to interrupt current under over-current/abnormal conditions (resettable/thermal type), functioning as a circuit-protection apparatus. 5.3 The manufacturing flow placed on record is as follows: The above flow chart shows these items are purpose-built cell parts/inputs incorporated directly in lithium-ion cells. Issue of classification: 5.4. I have examined the submissions from both sides in light of Tariff entry and chapter/section/explanatory notes and application of General Rules of Interpretation (GRI). It is settled principle of law that the classification of any good under Customs Tariff Act, 1975 is governed by the General Rules for the Interpretation of the Import Tariff. Further, Rule 1 of GRI stipulates that "classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes." I have examined the competing headings and the relevant sec....
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....Miniature circuit breakers 8536 20 40 Earth leak circuit breakers 8536 20 90 Other 8536 30 00 Other apparatus for protecting electrical circuits Relays: 8536 41 00 -- For a voltage not exceeding 60 V 8536 49 00 -- Other 8536 50 - Other switches: 8536 50 10 --- Control and switch gears 8536 50 20 Other switches of plastic 8536 50 90 Other - Lamp-holders, plugs and sockets: 8536 61 -- Lamp-holders: 8536 61 10 -- Of plastic 8536 61 90 Of other materials 8536 69 -- Other: 8536 69 10 -- Of plastic 8536 69 90 --- Of other materials 8536 70 00 Connectors for optical fibres, optical fibre bundles or cables 8536 90 - Other apparatus: 8536 90 10 --- Motor starters for AC motors 8536 90 20 --- Motor starters for DC motors 8536 90 30 Junction boxes 8536 90 90 Other 8545 CARBON ELECTRODES, CARBON BRUSHES, LAMP CARBONS, BATTERY CARBONS AND OTHER ARTICLES OF GRAPHITE OR OTHER CARBON, WITH OR WIT....
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....parts which are suitable for use solely or principally with a particular kind of machine, or with machines of the same heading, are to be classified along with the machine for which they are designed. The rule thus ensures that where a part is devoted exclusively or predominantly to a particular machine, it is classified with that machine. The Note also clarifies that if a part is equally suitable for use with goods of headings 8517 or 8525 to 8528, it must be classified under heading 8517. Only when a part is neither specifically provided for under Note 2(a), nor suitable for use solely or principally with a particular type of machine under Note 2(b), does the Note 2(c) is applied. This clause directs such residual parts to one of a set of generic "parts" headings, namely headings 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538, and if classification still cannot be determined, then finally to heading 8485 or 8548. 5.6 I now take up the issue of classification of each of the items to be imported by the applicant separately: 5.6.1. Cathode coated foil: I note from the submissions and material placed on record that the goods in question consist of aluminium current-coll....
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....s and noting that graphite is the predominant component of the film, the applicant has contended that the goods fall under Heading 8545 by virtue of Section Note 2(a) to Section XVI. The applicant has also referred to judicial precedents that slitting or cutting to required size does not alter the essential character of a product that is already identifiable as a part at the time of import. 5.6.3.1 Having considered the submissions as well as the views of the jurisdictional Commissionerate, I note that a divergence exists between the tariff position proposed by the applicant CTI 8545 19 00 and that urged by the Department under CTI 8507 90 90. Upon examination of the scope of the competing headings, it is evident that Heading 8545 is intended to cover "carbon electrodes, carbon brushes, lamp carbons, battery carbons and other articles of graphite or other carbon, with or without metal, of a kind used for electrical purposes." These entries are in the nature of generic carbon components such as furnace electrodes, carbon brushes, lamp carbons and the traditional carbons used in dry-cell batteries. On the other hand, Tariff Heading 8507 covers "electric accumulators, including sep....
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....e applicant has therefore asserted that the product is not a generic plastic film but a highly specialised component designed solely and principally for use in accumulators of Heading 85.07. 5.6.4.1 The applicant has further submitted that the product is not covered under any specific heading of Chapters 84 or 85 within the meaning of Section Note 2(a) to Section XVI. Consequently, the classification of the goods must be determined in accordance with Section Note 2(b), which mandates that parts suitable for use solely or principally with a particular machine are to be classified along with that machine. Reliance has also been placed on the HSN Explanatory Notes to Heading 8507, which expressly refer to separators- including those imported in rolls and merely cut to size-provided they meet the technical criteria for accumulator use. Judicial precedents cited, including Exide Industries Ltd. [2007 (212) E.L.T. 496 (Tri .- Chennai)] and Amara Raja Batteries Ltd. [2008 (228) E.L.T. 117 (Tri .- Chennai)], also support the position that accumulator separators, even in roll form, retain their identity as parts of accumulators at the time of importation. 5.6.4.2 In evaluating the com....
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.... this heading also elaborate that circuit- protective devices, including those employing thermal or over-current protection mechanisms, fall within its scope. The LC Breaker, as described, is an independent protective apparatus designed to interrupt current flow in the event of unsafe operating conditions. It performs this function autonomously and is not a passive component of an accumulator. 5.6.5.2 I therefore observe that the product cannot be brought within Heading 8507, which pertains to electric accumulators and parts thereof. Heading 8507 is limited to the electrochemical and mechanical components essential to accumulator construction (such as plates, separators and cases) and does not extend to active electrical protective devices. The LC Breaker is a distinct electrical apparatus that interacts with, but does not form an integral part of the accumulator; it protects the circuit rather than participating in the electrochemical storage process. 5.6.5.3 Accordingly, by application of General Interpretative Rule 1, read with the statutory text of Heading 8536 and the relevant HSN Notes, the LC Breaker is appropriately classified under CTI 8536 30 00, covering "Other app....
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....& Co. Ltd., 2004 (170) ELT 129 (SC), wherein the Court held that although exemption notifications must be construed strictly, such interpretation must not defeat the object and purpose of the exemption itself. In the present case, the evident legislative intent is to support and incentivise domestic manufacture of lithium-ion cells by permitting import of their essential inputs and parts at a concessional rate of duty. A narrow or technical reading that excludes functionally indispensable components would undermine this objective and would not be in consonance with the ratio of the above judgment. 5.7.4 Having regard to the wording of Serial No. 314, its chapter-neutral ambit, the purpose sought to be achieved, and the functional role of the goods under consideration, I conclude that the benefit of Notification No. 45/2025-Customs dated 24.10.2025 is available to all four items, subject to strict compliance with Condition No. 3 of the Notification (IGCR, 2022 procedure) and actual end-use in the manufacture of lithium-ion cells falling under tariff item 8507 60 00. 6. For the reasons recorded in the foregoing discussion and findings, I rule as under: 6(a) Cathode coa....