TaxTMI 
TaxTMI 
TaxTMI 
2025 (12) TMI 1395
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....a wholly owned subsidiary of Daifuku Japan, a global leader in material handling automation. They submitted that Daifuku provides end-to-end solutions encompassing consulting, planning, design, manufacturing, installation, after-sales service, maintenance, upgrading, and retrofitting, leveraging their extensive experience to design optimal systems tailored to customer requirements. They explained that Daifuku had developed Japan's first automated storage and retrieval system (AS/RS) in 1966, with objectives such as reducing workload, achieving cost savings through efficient land use, improving storage efficiency, saving labour in warehouse operations, and enhancing management standards. 2.2 Further, it is submitted that AS/RS systems enable warehouses to become three-dimensional and automated and are predominantly used for storing finished goods and raw materials. The applicant indicated that their Unit Load AS/RS system, classified under HS Code 84289090, is recognized globally for its high-density pallet storage, rapid operation, and adaptability, with designs extending up to 40 meters to accommodate varied installation environments and operational needs. They described fe....
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....e systems for these conveyors include low- profile 24 VDC motors for energy-efficient and silent functioning, as well as heavy-duty AC motors ranging from 1/2 HP to 5 KVA operating at 240/440 VAC. It was also highlighted that these conveyors are equipped with guard rails and structural supports to ensure operational safety and system integrity, and that the frame and other components are built to withstand continuous use. As regards performance, the applicant submitted that Roller Conveyors offer a speed range of 10 to 60 meters per minute, with live load capacity varying depending on the roller type and motor configuration. The design is optimized to allow smooth handling of different load sizes. These conveyors, as submitted, are ideally suited for packaging lines, warehouse automation, sorting systems, and other applications that necessitate controlled and contact-free product movement and accumulation. 2.7 As regards of the Sorter Conveyors submitted that they are precision- engineered systems made using high-quality mild steel and are tailored for a variety of warehouse and manufacturing applications. It was stated that these conveyors are designed to deliver operational ef....
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....ule of the Customs Tariff Act, 1975, its corresponding Chapter notes, supplementary notes and relevant HSN explanatory notes. At the outset, we find that the issue raised in the first question is squarely covered under Section 28H(2)(a) of the Customs Act, 1962 being a matter related to classification of goods under the provisions of this Act. 4.1 Upon a thorough and detailed examination of the submissions and technical documents provided by M/s Daifuku Intralogistics India Pvt. Ltd., it is recorded that the applicant is a wholly owned subsidiary of Daifuku Japan, a globally renowned leader in material handling automation and that they possess extensive expertise in delivering end-to-end solutions, including consulting, system planning, engineering design, manufacturing, installation, after-sales service, maintenance, upgrades, and retrofitting, reflecting its technological strength and comprehensive industry capabilities. They also claim that they pioneered Japan's first Automated Storage and Retrieval System (AS/RS) in 1966, aiming to maximize warehouse space, reduce operational and labour costs, enhance storage efficiency, and improve intralogistics management. The applic....
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....ild steel, are engineered for high-speed, precision sorting of cartons and packaged goods at designated points. Operating at speeds of 10 to 45 meters per minute and powered by comparable drive units, they are equipped with accurate tracking mechanisms and structural reinforcements to ensure reliability in high-throughput applications. In view of their construction, function, and usage in mechanical handling of materials within industrial systems- specifically for sorting, conveying, and accumulating packages-these machines exhibit the essential characteristics of conveying equipment that is powered and mechanically driven. 4.4 It is observed that, both technologically and functionally, roller conveyors and sorter conveyors, as described by the applicant, are mechanical apparatus explicitly designed for the conveying or sorting of goods along a fixed path within an intralogistics or warehouse environment. These machines comprise integral components such as mechanically driven rollers, belts, diverters, drive motors, sensors, and control systems, all of which work cohesively to ensure the independent performance of essential material handling tasks, whether in transporting goods ....
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....e legal scope of Heading 8431 is thus confined to articles which, by their nature, function solely or principally as components integral to the operation of machinery classified under those specific headings. In contrast, Roller Conveyors and Sorter Conveyors do not fall within this definition, as they are not merely auxiliary attachments or subordinate mechanical elements. Instead, they are independently operating mechanical devices, purposefully built to execute distinct mechanical functions crucial to the automated movement and sorting of goods. 4.8 Structurally, these conveyors incorporate driven rollers, belts, diverters, motor assemblies, sensor arrays, and sophisticated control systems, all integrated to perform highly specialized tasks. This complex composition enables them to function autonomously, executing precise processes such as accumulating products for orderly flow, directing items along predetermined paths, detecting and diverting items based on programmed criteria, and ensuring seamless logistics operations. Their inherent ability to perform such tasks underscores their character as self-contained mechanical apparatus possessing both mechanical identity and ope....
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....goods must be determined according to the specific terms of the tariff headings and the relevant Section or Chapter Notes, rather than solely by reference to the end-use of the goods 4.13 This position has been firmly upheld by the Hon'ble Supreme Court in a series of significant judicial pronouncements. In Fenner (India) Ltd. v. Collector of Central Excise, Madurai [1995 (77) E.L.T. 561 (S.C.)], the Court unequivocally held that the classification of goods under the Central Excise Tariff must be determined in accordance with the specific terms of the headings and applicable Section or Chapter Notes, rather than being dictated solely by the end-use of the product. The Court underscored that the essential character and composition of the goods, rather than their intended application, are decisive in determining classification. 4.14 Similarly, in Commissioner of Central Excise, Delhi v. Carrier Aircon Ltd. [2006 (199) E.L.T. 577 (S.C.)], the Hon'ble Supreme Court held that the end-use of a product cannot govern its classification when the product is specifically covered under a particular tariff heading. The Court emphasized that even if a product is predominantly used ....