TaxTMI 
TaxTMI 
2025 (12) TMI 1077
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.... Private Limited (hereinafter referred to as the "Applicant") is a Private Limited Company duly incorporated under the provisions of the Companies Act, 1956, having its registered office at Legend-Gold Leaf Premises 3/A,3rd Floor No: 3-4-559 to 566, Narayanaguda, Hyderabad, Telangana 500 029. 2.2 The Applicant is a subsidiary of Weiss Umwelttechnik GmbH, a leading German manufacturer of a wide range of equipment/products in the fields of environmental simulation, heating technology, and plant growth chambers. 2.3 The Applicant specializes in the sales, training, and service of the equipment manufactured by its parent company to various industries, including automotive, electronics, pharmaceuticals. These equipments are manufactured outside India and are regularly imported by the Applicant for domestic trading and training purposes. Import of Climatie Test Chambers: 2.4 The Applicant has been importing 'Climatic Test Chambers', and classifying the same under Heading 84.79 of the Customs Tariff as Machines and mechanical appliances having individual functions not specified or included elsewhere in this chapter'. About the product in question: 2.5 Climati....
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....rol +Humidity - 9. EXCAL Temperature +Humidity Control - 10. SunEvent Temperature Control +Humidity Solar Simulation Testing 11. SkyEvent Temperature +Humidity Control Pressure Variation Testing Process Flow Chart on usage of Climatic Test Chambers: 2.9 The following flow chart provides detailed analysis on the usage and functions of the Climatic Test Chambers: Test Preparation * Specimen Placement: The product or material to be tested is placed inside the Climatic Test Chamber. * Program Configuration: Using the WEBSeasonk interface or SIMPATIR software or the permanently mounted TFT Screen, test parameters stich as temperature ranges, humidity levels, and duration are set. Environmental Simulation * Temperature Control: The Climatic Test Chamber has a heating and cooling system that can simulate temperatures ranging from -70°C to +180ºC", with rapid change rates up to 25 K/min. depending on the model. * Humidity Control: With the humidity control unit on the device, relative humidity can be controlled between 10% and 98%, achieved through a thermally controlled water bath system that p....
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....essing changes in color, transparency, and gloss. * Weight Changes: Measuring any changes in weight, which can indicate material loss or absorption. * Fatigue and Wear: Evaluating the specimen's resistance to repeated stress and wear over time 2.10 In view of the above, it is correct to state that the Climatic Test Chambers are devices/equipment designed for conducting physical analysis of products under various climatic conditions. Applicant's interpretation of Law/Facts 3.1 The Applicant submits that "Climatic Test Chambers are classifiable under Heading 90.27, specifically Tariff Item 9027 89 90 of the Customs Tariff as "Instrument and apparatus for physical analysis: Other: Other". 3.2 Heading 90.27 covers 'Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes'. Tariff Item INSTRUMENTS AND APPA....
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....ntify and analyse the behaviour of the specimen under specific climatic conditions. In other words, the viewing window enables the person conducting the test to analyse expansion or contraction of the specimen at a particular temperature/humidity level. 3.8 Further, the classification of "Climatic Test Chambers' under Chapter 90 of the Customs Tariff is also supported by the HSN to Chapter 90. 3.9 In the HSN, the General Note (I) to Chapter 90 specifically provides that this Chapter inter alia covers instruments and apparatus "for scientific purposes (laboratory research work, analysis, astronomy, etc.), for specialised technical or industrial purposes (measuring or checking, observation, etc.) or for medical purposes". Furthermore, the General Note (1) to Chapter 90 also specifically states that this chapter includes in particular "machines, instruments and appliances for testing materials". 3.10 The 'Climatic Test Chambers manufactured by the parent company of the Applicant are used for testing of products manufactured by various sectors including the automotive, electronics, pharmaceuticals. All these specified industries use the product in question to ensure th....
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.... Ruling on classification of Climatic Test Chambers manufactured by Applicant's parent company also specify that the Climatic Test Chambers are classifiable under Heading 90.27 as "apparatus for physical examination". The BTI Ruling in favour of Applicant's parent company along with its English translation are collectively enclosed herewith as Exhibit -4 to the application. 3.13 In view of the above, the Applicant submits that Climatic Test Chambers are correctly classifiable under Heading 90.27 of the Customs Tariff. 3.14 Furthermore, it is pertinent to note that the High-precision Psychrometric Sensors that are fitted in the Climatic Test Chambers are also specifically covered in the Chapter 90. Heading 90.25 of the Customs Tariff reads as follows "Hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and any combination of these instruments". 3.15 Since psychrometer, which is one of the components of Climatic Test Chambers, is specifically classifiable under Chapter 90, the Climatic Test Chambers are also correctly classifiable under Heading 90.27 as they perform the function of compl....
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....a rule. characterised by their high finish and high precision. Most of them are used mainly for scientific purposes (laboratory research work, analysis, astronomy, etc.), for specialised technical or industrial purposes (measuring or checking, observation, etc.) or for medical purposes. 6.3 Explanatory Notes to the Combined Nomenclature of the European Union specifically provides that sub Heading 9027 80 99 includes climatic testing cupboards/chambers wherein specimen are exposed to environmental conditions (specific temperature and humidity conditions) to test their service life, insulation, etc. Relevant EU Explanatory Note is provided at page 19 - 21 of the Compilation and snapshot of the relevant portion is reproduced below: 9027 80 99 Other - This subheading includes climatic testing cupboards equipped with a pressure chamber, an electric heater, an air humidifier and an electric unit, in which electronic components are exposed to specific pressure, temperature and humidity conditions, simulating the influences and environmental conditions occurring in their subsequent use, in order to test their service life, insulation, etc. 6.4 The subject goods in ....
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....l parameters of the specimen by the climatic chambers for visual observation is a good enough criterion for the purposes of classifying them under Heading 90.27. Globally, the classification of the subject goods is also aligned at the six-digit tariff level. Hence, it is submitted that Climate Test Chambers are correctly classifiable under Tariff Item 9027 89 90 of the Customs Tariff. Discussion and findings 7.1 I have carefully considered all the materials placed before me in respect of the subject goods. I have also examined the submissions made by the applicant during the personal hearing as well as the additional written submissions. Accordingly, I proceed to pronounce my ruling on the basis of the information available on record and within the framework of the applicable legal provisions. 7.2 At the outset, I find that the issue raised in the question in the Form CAAR-1 is squarely covered under Section 28H(2) of the Customs Act, 1962, being a matter related to classification of goods under the provisions of this Act. 7.3 Before deciding the issue, let me deliberate on the legal framework prescribed in Customs Tariff Act, 1975, Chapter/ Section notes along with HSN....
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....ging its chemical composition. A climatic chamber does not change the chemical composition of the sample, but it exposes the material to controlled environmental stresses (heat, cold, moisture, etc.) to measure physical responses such as expansion, contraction, warping, cracking, or strength loss. Accordingly, a climatic test chamber is used for the physical analysis of durability, stability, and performance of the product, material or component. 7.6 I note that the Chapter Tariff Heading 9027 covers "instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes.". The relevant portion of CTH 9027 is reproduced below for ease of reference: Subheading/ Tariff Item Dash Description 9027 - Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis appar....
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....ntraction, warping, cracking, fading, or strength loss. For instance, metals and plastics may expand in heat and contract in cold, electronics may warp or malfunction under high humidity, coatings may peel or fade under UV exposure, and mechanical parts may show fatigue or cracking under combined vibration and temperature cycles. These outcomes represent changes in physical properties that can be observed, measured, and quantified without altering the inherent chemical nature of the material. In this manner, the Climatic Test Chamber provides a reliable means of assessing durability. stability, and performance of products, thereby serving as an apparatus for physical analysis. 7.9 Based on the technical data and supporting documentation submitted by the applicant, it is evident that the Climatic Test Chamber qualifies as an apparatus for physical analysis. Heading 9027 of the First Schedule to the Customs Tariff Act, 1975, specifically covers instruments and apparatus for physical or chemical analysis. Accordingly, in terms of General Interpretative Rule 1 (GIR 1) read with the HSN Explanatory Notes, the subject goods, namely Climatic Test Chambers, merit classification under He....