TaxTMI 
TaxTMI 
2025 (12) TMI 1626
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....ir application has submitted as follows: 2.1 The applicant is importing various parts of Reducer (hereinafter referred to as the "reducer"/ "the subject good") through air. A picture of the finished good is attached hereunder: 2.2 The parts in question are parts of Reducer for use with the electric Axle (hereinafter referred to as "eAxle") of electric vehicles. The 3-in-1 eAxle integrates an electric motor, inverter, and reducer into a single, compact unit within a unified housing. The Table-1 below shows the list of parts of the reducer for which the Applicant seeks a Ruling on classification. TABLE-I SI. No. Description 1. B Shield 2. Oil Protective Plug 3. Dowell Pin 4. Differential Assembly 5. INTERMEDIATE SHAFT SUB- ASSEMBLY 6. Final wheel / gear 7. Input shaft 8. Tapered Roller Bearing ID80 and ID90 9. Ball Bearing ID40 10. Breather 11. SNAP RING D40 12. Output Radial Lip Seal The above listed parts are used in the manufacture of reducer for use with the eAxle of electric vehicles. The remaining components needed to assemble a complete electric motor are procured domestically by the Appl....
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.... India, covered by different purchase Orders and therefore will arrive in India in different shipments. Applicant's interpretation of Law/Facts 2.7 The applicant's understanding that the parts of the "Reducer" in question listed in Table - 3 to the application cannot be classified under any other heading in the Customs Tariff Schedule other than those indicated in Table - 3 for the respective parts. 2.7.1 CLASSIFICATION OF PARTS OF REDUCER SOUGHT TO BE IMPORTED. Classification of parts of Reducer identifiable for use solely or principally with the Reducers * The applicant submits the Reducer being a transmission meant for use with the eAxle of electric vehicles merits classification under CTH 8708 in terms of GIR1 read with Note 3 to Section XVII. * The first schedule to the Customs Tariff Act, 1975 sets out the General Rules of Interpretation ("GRIs") which are to be applied to determine classification under the Customs Tariff. * GRI 1 provides that classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods canno....
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....arts of reducer proposed to be imported by the applicant will be as shown in the Table-II below: SI. No. Description HSN Code 1. B Shield 87084000 2. Oil Protective Plug 87084000 3. Dowell Pin 73182900 4. Differential Assembly 87084000 5. INTERMEDIATE SHAFT SUB-ASSEMBLY 87084000 6. Final wheel/ gear 87084000 7. Input shaft 87084000 8. Tapered Roller Bearing D85 and D90 84822012 9. Ball Bearing D80 84821052 10. Breather 87084000 11. SNAP RING D40 87084000 12. Output Radial Lip Seal 39269029 The Applicant submits that each component is independently sourced and imported as per operational demand, rather than as a pre-packaged unit or kit. The imports are procured from different suppliers under separate Memoranda of Understanding (MOUs) and are received through multiple shipments in varying order quantities, based on production requirements. Given this procurement structure, the classification of each part should be determined individually based on its inherent characteristics, taking into account the independent nature of each imported part. Port of Import and....
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....ric vehicles. according to Rule 1, titles of Section and Chapters in the Schedules are provided for ease of reference only. For legal purposes, classification shall be determined according to the terms of the headings and any relevant section or Chapter Notes. The other rules for interpretation shall be required only when the relevant Heading or Section Notes are not sufficient to lead to a definitive classification. "SECTION XVII VEHICLES, AIRCRAFT, VESSELS AND ASSOCIATED TRANSPORT EQUIPMENT NOTES: 2. The expressions "parts" and "parts and accessories" do not apply to the following articles, whether or not they are identifiable as for the goods of this Section: ... (e) machines and apparatus of headings 8401 to 8479, or parts thereof, other than the radiators for the articles of this Section, articles of heading 8481 or 8482 or, provided they constitute integral parts of engines and motors, articles of heading 8483. (emphasis supplied) 3. References in Chapters 86 to 88 to "parts" or "accessories" do not apply to parts or accessories which are not suitable for use solely or principally with the articles of those Chapters. A ....
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....o match the vehicle's speed chosen by the driver. Therefore, the reducer is in the nature of a gear box or differential. 6.8 Under CTH 8708 the appropriate Tariff Item will be 87084000 which is specific to, "Gear boxes and parts thereof". As the reducer playing the role of a differential or gear box and transmitting motive power to the wheels directly, the reducer would merit classification under CTH 87084000 which reads as follows: 87084000 - Gear boxes and parts thereof Therefore, classification of the reducer will be appropriate under CTH 87084000. 7.1 Now, I will discuss the classification of the parts of the "Reducer". Note 2 and note 3 of section XVII provides that : 2 .- The expressions "parts' and «parts and accessories" do not apply to the following articles, whether or not they are identifiable as for the goods of this Section: (a) Joints, washers or the like of any material (classified according to their constituent material or in heading 84.84) or other articles of vulcanised rubber other than hard rubber (heading 40.16); (b) Parts of general use, as defined in Note 2 to Section XV, of base metal (Section XV), o....
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....racted below: (D) Gear boxes (transmissions) of all types (mechanical, overdrive, preselector, electro-mechanical, automatic, etc.); torque converters; gear box (transmission) casings; shafts (other than internal parts of engines or motors); gear pinions; direct-drive dog-clutches and selector rods, etc. (E) Drive-axles, with differential; non-driving axles (front or rear); casings for differentials; sun and planet gear pinions; hubs, stub-axles (axle journals), stub-axle brackets. (F) Other transmission parts and components (for example, propeller shafts, half-shafts; gears, gearing; plain shaft bearings; reduction gear assemblies; universal joints). But the heading excludes internal parts of engines, such as connecting-rods, push-rods and valve lifters of heading 84.09 and crank shafts, cam shafts and flywheels of heading 84.83. Applied to the Reducer in question, the reducer itself is a gear box or a differential classifiable under CTH 87084000. Therefore, it could be noted that parts of gear boxes are also covered under the same Tariff Item. Therefore, it can be said that B Shield, Oil Protective Plug, Differential Assembly, Intermediate Shaft Sub-....
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....: --- Adapter ball bearings (radial type) : 8482 10 11 ---- Not exceeding 50mm of bore diameter 8482 10 12 ---- Of bore diameter exceeding 50 mm but not exceeding 100 mm 8482 10 13 - Of bore diameter exceeding 100 mm 8482 10 20 --- Other ball bearing (radial type) of bore diameter not exceeding 50 mm 8482 10 30 --- Other ball bearing (radial type) of bore diameter exceeding 50 mm but not exceeding 100 mm 8482 10 40 --- Of bore diameter exceeding 100 mm --- Thrust ball bearings : 8482 10 51 ---- Of bore diameter not exceeding 50 mm 8482 10 52 ---- Of bore diameter exceeding 50 mm but not exceeding 100 mm 8482 10 53 ---- Of bore diameter exceeding 100 mm 8482 10 90 --- Other 8482 20 - Tapered roller bearings, including cone and tapered roller assemblies : --- Tapered roller bearings (radial type) : 8482 20 11 ---- Of bore diameter not exceeding 50 mm 8482 20 12 ---- Of bore diameter exceeding 50 mm but not exceeding 100 mm 8482 20 13 ---- Of bore diameter exceeding 100 mm 8482 20 90 &nb....