TaxTMI 
TaxTMI 
2025 (12) TMI 1748
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....pany is a leader in passenger car segment, engaged in the manufacture of automobile components. The applicant is a preferred supplier to automotive majors in the country. The applicant is importing various parts of Inverter (hereinafter referred to as the "Inverter"/ "the subject good") through air. A picture of the finished good is attached hereunder: 2.2 The parts in question are parts of inverter 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 Inverter for which the Applicant seeks a Ruling on classification. TABLE-I SI. No. Description 1. Housing PMA Inverter (2.772 kg/gw) 2. PMA Bracket PCB C (0.616 kg/gw) 3. PMA Cooler (0.407/gw) 4. PMA DC Busbars 5. Hall Sensor protection (PMA N60) 6. E-form Ferrite 7. Ferrite Inside DC Filter CN 8. PMA Toroid DC Filter 9. Cover Inverter PMA-NVH 10. Gap Pad Ferrite Base+ CN 11. Thermal Foil FOR MOSFET 12. Gap Pad DC Link Bus bar 13. DC-LINK Ca....
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....are identifiable for use solely or principally with the inverter proposed to be imported by the Applicant. In this application the applicant seeks a determination of the classification of different parts of the inverter proposed to be imported by them. While a number of components required for assembly of a complete inverter are procured domestically by the Applicant. 3. Applicant's interpretation of Law/Facts 3.1. The applicant submits the inverter meant for use with the e-Axle of electric vehicles merits classification under CTH 8504 in terms of GRI 1. The objective of the present application is not to seek the classification of the inverter which emerges during the assembly operations carried out in India from the components proposed to be imported and also the components procured from the domestic market. 3.2. Section 2 of the Customs Tariff Act, 1975 specifies that the rates at which duties of customs shall be levied for imported goods will be specified under the First Schedule. 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. 3.....
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....1 to this Section, Note 1 to Chapter 84 and to Note 1 to Chapter 85, parts of machines (not being parts of the articles of heading 8484, 8544, 8545, 8546 or 8547) are to be classified according to the following rules: (a) parts which are goods included in any of the headings of Chapter 84 or 85 (other than headings 8409, 8431, 8448, 8466, 8473, 8485, 8503, 8522, 8529, 8538 and 8548) are in all cases to be classified in their respective headings; (b) other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading (including a machine of heading 8479 or 8543) are to be classified with the machines of that kind or in heading 8409, 8431, 8448, 8466, 8473, 8503. 8522, 8529 or 8538 as appropriate. However, parts which are equally suitable for use principally with the goods of headings 8517 and 8525 to 8528 are to be classified in heading 8517, and parts which are suitable for use solely or principally with the goods of heading 8524 are to be classified in heading 85291; (c) all other parts are to be classified in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropria....
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.... However, this office has only received comments/response in this matter from ACC, Mumbai vide letter dated 09.12.2025 wherein it is submitted that the Department has made the following observations regarding the technical and legal evaluation of cach goods/products : 4.1 Items independently classifiable under their own headings (Note 2(a) of Section Note XVI) Sr. No. Item No. Description HS Code Department View 1 4 DC Busbars 85369090 Correct - busbars are electrical connectors 2 6 Ferrite Core 85051110 Correct 3. 7 Ferrite - DC Filter 85051110 Correct 4 8 Toroid DC Filter 85051190 Correct 5 10 Thermal Foil 85469090 Appears correct - electrical insulator 6 11 Gap Pad (Ferrite Base) 85469090 Correct 7 12 Gap Pad - DC Link 85469090 Correct 8 13 DC Link Capacitor 85321000 Correct - fixed capacitor 9 16 HVDC Connector 85369090 Correct 10 18 Warning Label 39199010 Correct 4.2 Items falling under Note 2(b) as parts of an inverter The following items are claimed under 85049090. (i) Housing } These are design....
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....ems are classifiable under Section XVI Note 2(a) / 2(b) as proposed. 3. The IGBT module is more appropriately classifiable under CTH 8541, subject to datasheet verification. 4. Notification 57/2017-Cus appears applicable to items correctly falling under 8504 90 90. Details of Hearing 5.1 A hearing was held on 26.11.2025 at 03.00 PM. Shri P. Sridharan, Sr. Advocate appeared online for PH in the matter on behalf of the applicant. He reiterated the contention submitted with the application. He submitted that the subject import goods are parts of inverter which convert DC power to AC power. There are 18 different parts that are mentioned specifically in the Customs tariff Act. He contended that even if these parts are to be used in manufacture/assembly of inverter- the inverter (with other 2 major components e- motor and reducer in making 3-in-1 electric axle of motor vehicle) will not merit classification under CTH 8708. He further contended that all the components (18) will be imported in different shipment and from different supplier. He submitted that CTH 8504 specifically covers inverter or static converters, hence in terms of section note 2(a) and 2(b) ....
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....FT, 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: ...: (f) electrical machinery or equipment (Chapter 85). " It is therefore apparent that parts or parts/ accessories of motor vehicles specified in Note 2 to Section XVII will not be regarded as parts or parts /accessories and classified under CTH 8708, even when they are identifiable for use with the vehicles of Chapter 87. 6.6 Application of Chapter 85 Electrical machinery and equipment and parts thereof; sound recorders and reproducers, television image and sound recorders and reproducers, and parts and accessories of such articles 8504 ELECTRICAL TRANSFORMERS, STATIC CONVERTERS (FOR EXAMPLE, RECTIFIERS) 8504 10 - Ballasts for discharge lamps or tubes : 8504 10 10 Conventional type u 8504 10 20 For compact fluorescent lamps u 8504 10 90 Other Liquid dielectric transformers: u 8504 21 00 Having a power handling capacity not-exceeding 650 kVA  ....
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....ssified in their respective headings; (b) other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading (including a machine of heading 8479 or 8543) are to be classified with the machines of that kind or in heading 8409. 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate. However, parts which are equally suitable for use principally with the goods of headings 8517 and 8525 to 8528 are to be classified in heading 8517, and parts which are suitable for use solely or principally with the goods of heading 8524 are to be classified in heading 85291: (c) all other parts are to be classified in heading 8409, 8431, 8448, 8466. 8473. 8503, 8522, 8529 or 8538 as appropriate or, failing that, in heading 8485 or 8548." 6.8 Note 2 to Section XVI is subject to the exclusions under Note 1 to Section XVI. An example of such an exclusion is provided in Note 1(a) ibid as shown below: "SECTION XVI NOTES: 1. This Section does not cover: (a) transmission or conveyor belts or belting, of plastics of Chapter 39, or of vulcanized rubber (heading 4010); or other articles o....
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....the same heading, are classified in the same heading as those machines or apparatus subject of course, to the exclusions mentioned in Part (1) above. Separate headings are, however, provided for: (A) Parts of the engines of heading 84.07 or 84.08 (heading 84.09). (B) Parts of the machinery of headings 84.25 to 84.30 (heading 84.31). (C) Parts of the textile machines of headings 84.44 to 84.47 (heading 84.48). (D) Parts of the machines of headings 84.56 to 84.65 (heading 84.66). (E) Parts of the office machines of headings 84.70 to 84.72 (heading 84.73). (F) Parts of the machines of heading 85.01 or 85.02 (heading 85.03) (G) Parts of apparatus of headings 85.19 or 85.21 (heading 85.22). . (H) Parts of apparatus of headings 85.25 to 85.28 (heading 85.29). (IJ) Parts of apparatus of heading 85.35,85.36 or 85.37 (heading 85.38). 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 sp....
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.... only to those parts or accessories which comply with all three of the following conditions : (a) They must not be excluded by the terms of Note 2 to this Section (see paragraph (A) below). and (b) They must be suitable for use solely or principally with the articles of Chapters 86 to 88 (see paragraph (B) below). and Fr (c) They must not be more specifically included elsewhere in the Nomenclature (see paragraph (C) below). (A) Parts and accessories excluded by Note 2 to Section XVII. This Note excludes the following parts and accessories, whether or not they are identifiable as for the articles of this Section: (1) Joints, gaskets, washers and the like, of any material (classified according to their constituent material or in heading 84.84) and other articles of vulcanised rubber other than hard rubber (e.g., mudguard-flaps and pedal covers) (heading 40.16). (2) Parts of general use as defined in Note 2 to Section XV, for example, cable and . chain (whether or not cut to length or equipped with end fittings, other than brake cables, accelerator cables and similar cables suitable for use in vehicles of Chapter 87), nail....
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....5.01 or 85.04. (b) Electro-magnets, electro-magnetic clutches, brakes, etc., of heading 85.05. (c) Electric Accumulators (heading 85.07). (d) Electrical ignition or starting equipment of a kind used for spark-ignition or compression-ignition internal combustion engines (sparking plugs, starter motors, etc.) (heading 85.11). (e) Electrical lighting, signaling, windscreen wiping, defrosting, demisting; equipment for cycles or motor vehicles (heading 85.12); electrical signalling apparatus for other vehicles (e.g., trains) or for aircraft or ships (heading 85.31); electrical defrosters or demisters for such other vehicles, aircraft or ships (heading 85,43). (f) Electric heating units for motor or railway vehicles, aircraft, etc. (heading 85.16). (g) Microphones, loudspeakers and audio-frequency electric amplifiers (heading 85.18). (h) Radio transmitters and receivers (heading 85.25 or 85.27). (ij) Electrical capacitors (heading 85.32). (k) Pantographs and other current collectors for electric traction vehicles, and fuses, switches and other electrical apparatus of heading 85.35 or 85.36. (l) Elec....
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....ether or not printed, embossed, or impregnated; 3919 90 20 --- Cellulose adhesive tape 3919 90 90 --- Other The explanatory notes provides that this heading covers all self-adhesive flat shapes of plastics, whether or not in rolls, other than floor, wall or ceiling coverings of heading 39.18. The heading is, however limited to flat shapes which are pressure-sensitive, i.e., which at room temperature, without wetting or other addition, are permanently tacky (on one or both sides) and which firmly adhere to a variety of dissimilar surfaces upon mere contact, without the need for more than finger or hand pressure. It should be noted that this heading includes articles printed with motifs, characters or pictorial representations which are not merely subsidiary to the primary use of the goods (see Note 2 to Section VII). Therefore, in view of the GRI 1, heading and explanatory notes, it is clear that Self- adhesive label made of Plastic are Classifiable under CTH 39199010. 6.9.3 CTH 8505 provides- ELECTRO-MAGNETS; PERMANENT MAGNETS AND ARTICLES INTENDED TO BECOME PERMANENT MAGNETS AFTER MAGNETISATION; ELECTRO-MAGNETIC OR PERMANENT MAGNET CHUCKS, CLAMPS AND SIM....
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....) 8532 10 00 - Fixed capacitors designed for use in 50 or 60 Hz circuits and having a reactive power handling capacity of not less than 0.5 kvar (power capacitors) Classification of the fixed capacitors under CTH 85321000 will be appropriate in terms of Note 2(a) to Section XVI. 6.9.5 CTH 8536 covers- ELECTRICAL APPARATUS FOR SWITCHING OR PROTECTING ELECTRICAL CIRCUITS, OR FOR MAKING CONNECTIONS TO. OR IN ELECTRICAL CIRCUITS (FOR EXAMPLE, SWITCHES, RELAYS, FUSES, SURGE SUPPRESSORS, PLUGS, SOCKETS, LAMP-HOLDERS AND OTHER CONNECTORS, JUNCTION BOXES), FOR A VOLTAGE NOT EXCEEDING 1,000 VOLTS: CONNECTORS FOR OPTICAL FIBRES, OPTICAL FIBER BUNDLES OR CABLES. 8536 90 90 --- Other The explanatory notes provides- (III) APPARATUS FOR MAKING CONNECTIONS TO OR IN ELECTRICAL CIRCUITS This apparatus is used to connect together the various parts of an electrical circuit. It includes : (A) Plugs, sockets and other contacts for connecting a movable lead or apparatus to an installation which is usually fixed. This category includes: (1) Plugs and sockets (including those for connecting two movable leads). A plug may have one or more pi....
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....VICES (FOR EXAMPLE, DIODES, TRANSISTORS, *** SEMICONDUCTOR-BASED TRANSDUCERS); PHOTOSENSITIVE SEMICONDUCTOR DEVICES, INCLUDING PHOTOVOLTAIC CELLS WHETHER OR NOT ASSEMBLED IN MODULES OR MADE UP INTO PANELS; LIGHTEMITTING DIODES (LED), WHETHER OR NOT ASSEMBLED WITH OTHER LIGHTEMITTING DIODES (LED); MOUNTED PIEZO-ELECTRIC CRYSTALS - Transistors, other than photosensitive transistors : 8541 21 00 -- With a dissipation rate of less than 1 W 8541 29 00 - Other Further, explanatory notes also provide that (II) Transistors are three- or four- terminal devices capable of amplification, oscillation, frequency conversion, or switching of electrical currents. The operation of a transistor depends on the variation in resistivity between two of the terminals upon the application of an electric field to the third terminal. The applied control signal or field is weaker than the resulting action brought about by the change in resistance and thus amplification results. Transistors include : (1) Bipolar transistors, which are three-terminal devices consisting of two diode type junctions, and whose transistor action depends on both positive and negative charge carr....
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....apes. Certain types are constructed in such a way that when in position they may contain oil to prevent contamination of the surface by conducting materials. Insulators may be made of any insulating material, usually very hard and non-porous, e.g., ceramic material (porcelain, steatite), glass, fused basalt, hardened rubber, plastics or compounded insulating materials. They may contain fixing devices (e.g., metal brackets, screws, bolts, clips, laces, slings, pins, cross pieces, caps rods suspension or canying clamps). Insulators equipped with metal horns or guard shields or other devices to form lightning arresters are excluded (heading 85.35). Insulators are used on outdoor cables, e.g., in telecommunications, power networks, electrical traction systems (railway, tramway, trolleybus, etc.), and also for indoor installations or on certain machines and appliances. The insulators of this heading include: (A) Suspension insulators, such as : (1) Chain suspension insulators. These are used mainly on outdoor networks, and consist of several insulating elements. The conductor cable or wire is fixed at the bottom of the assembly which is hung on a suitabl....
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.... 8532, 8536, 8541 & 8546, the subject goods are classifiable under CTI as per the Table-III below of the First Schedule of the Customs Tariff Act, 1975- TABLE-III SI. No. Description of the goods HSN Codes 1. Housing PMA Inverter (2.772 kg/gw) 85049090 2. PMA Bracket PCB C (0.616 kg/gw) 85049090 3. PMA Cooler (0.407/gw) 85049090 4. PMA DC Busbars 85369090 5. Hall Sensor protection (PMA N60) 85049090 6. E-form Ferrite 85051110 7. Ferrite Inside DC Filter CN 85051110 8. PMA Toroid DC Filter 85051190 9. Cover Inverter PMA-NVH 85049090 10. Thermal Foil FOR MOSFET 85469090 11. Gap Pad Ferrite Base+ CN 85469090 1.2. Gap Pad DC Link Bus bar 85469090 13. DC-LINK Capacitor -carry over S230 85321000 14. 3 PCBA BOM Cost (PC+CU+EMC) including THT 85049090 15. IGBT FS820 85412900 16. TIVDC -Connector 85369090 17. Clip for ADR 85049090 18. Warning label 39199010 8. The applicant has requested that the ruling be kept confidential. The Authority has duly considered this request in light of Regulation 27 of the Customs Autho....
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....le part of an inverter. Classification under CTH 85049090 is appropriate in terms of Note 2(b) to Section XVI. Not excluded by Note I to Section XVI or Note 1 to Chapter 85 and also cannot be classified by application of Note 2(a) to Section XVI 2 Description: PMA- Bracket PCB-C (0.616 kg/gw) 85049090- Identifiable part of an inverter. Classification under CTH 85049090 is appropriate in terms of Note 2(b) to Section XVI. Not excluded by Note 1 to Section XVI or Note 1 to Chapter 85 and also cannot be classified by application of Note 2(a) to Section XVI. 3. Description: PMA-Cooler (0.407/gw) 85049090- Identifiable part of an inverter. Classification under CTH 85049090 is appropriate in terms of Note 2(b) to Section XVI. Not excluded by Note I to Section XVI or Note 1 to Chapter 85 and also cannot be classified by application of Note 2(a) to Section XVI 4 Description: PMA-DC- Busbars 85369090- Direct current bus bar- In the nature of a connector. Classification under CTH 85369090 is appropriate in terms of Note 2(a) to Section XVI. Not excluded by Note I to Section XVI or Note 1 to Chapter 85. 5. Description: Hall sensor protection- (PMA N60) 85049090- Identifiable p....