TaxTMI 
TaxTMI 
2025 (12) TMI 1746
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....of the First Schedule of the Customs Tariff Act, 1975, or otherwise. 2. Submission by the Applicant: 2.1 M/s Orpak Systems India Private Limited (hereinafter referred to as the "Applicant") is a fully owned subsidiary of M/s Orpak Systems Ltd, Israel. The Company has its registered office at SF No 627/2628/2, Sector W-4, PDP, Coimbatore Campus, Eachanari, Chettipalayam Road, INDL Estate Post, Malumichampatti, Coimbatore Industrial Estate, Coimbatore South, Coimbatore- 641021, Tamil Nadu, India. The Company is engaged in business of supply fuel dispenser, next- generation solutions for fuel retail and fleet management business. 2.2 Since the Quarter 4 of FY 2024-25, amongst other products, the Company is planning to import indicator panel incorporating Liquid-crystal display (LCD) screen, Decoder Integrated circuit (IC) & Processor IC having Model No as follows: Table 1 Part No Manf Part No. TS No. Item Description TRD-PMD-00078 XK25018 TS-SG01108003W LCD, COMBI, 7X2, 40mm Digit Height, Static Drive, COG, Reverse Contrast OR Ultrachip TRD-PMD-00103 XK25019 TS-SG01039011W LCD, 5 Digit, 25mm Digit Height, Static Drive, COG OR Ultrachip, ....
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....ommunication with other components of the dispenser. * Ensures accurate and timely display of information. ⮚ Aluminium Panel: * A sturdy metal panel that houses the integrated circuits and LCD screen. * Provides a protective enclosure and a mounting surface for the display. ⮚ Backlight: * An illumination source that provides background lighting for the LCD screen. * Enhances visibility in low-light conditions. The block design of a typical indicator panel is as below for reference: 2.6 These indicator panels can be tailored to display 4-6 digit as per the specific needs. This includes options for changing the size, display content, etc. They may also incorporate backlighting, touchscreen functionality etc. depending upon the need of the customer. The primary application for this kind of display is in fuel dispensers, where it provides essential information to consumers regarding fuel volume and price. This display screens offer a versatile and reliable solution for displaying numerical information in fuel dispensers and can also be used in various industrial applications that require clear and reliab....
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....orporated into other products before final use; * Flat panel display including additional components such as video signal receiver, pixel signal converter for displaying on screen etc., just beyond the display screen. 3.6 However, in terms of chapter note 7, CTH 8524 specifically excludes flat panel display modules with equipped with advanced components for converting video signals (e.g., scaler IC, decoder IC, application processor) or that have the characteristics of products in other headings. Therefore, it is pertinent to highlight that CTH 8524, doesn't include flat panel display modules which are equipped with components for converting video signal such as scaler IC, decoder IC, processor IC. 3.7 Basis the above submission, it can be concluded that the product under consideration would be outside the purview of CTH 8524 only if it contains a processor IC and a decoder IC that perform a critical function in converting video signals within the flat panel display. As enumerated in para 3-6 of Annexure A, in the case of product under consideration, it is clear that the flat panel display incorporates decoder IC as well as processor which undertake the conversio....
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....ls to control individual pixels receive video signals and display them on the screen. Such displays may incorporate backlight units (for LCDs) or frames; and * Flat panel display modules with touch-sensitive screens. 3.11 In the instant case, the product under consideration consists of segmented LCDs. A segmented display is a device comprising multiple independent segments arranged in such a way that the device can represent letters and/or numerals by selectively activating, i.e., turning on, specific segments of the display. These segments may be activated electrically (e.g., illuminated) or mechanically (e.g., uncovered). Reference is made to the patent information provided by the European Patent Office, accessible via the following link https://patents.google.com/patent/EP1183674A1/en. 3.12 It is submitted that a non-segmented display is made up of a grid of individual pixels which are capable of displaying more complex information such as higher resolution detailed images, videos, and various fonts or characters. In summary it can be said that Segmented panels are simple and ideal for basic numeric or alphanumeric displays, while non-segmented panels offer much m....
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....lls, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530 Items Covered Tariff Entry 8531 20 00 - Indicator panels incorporating liquid crystal devices (LCD) or light-emitting diodes (LED 3.17 In terms of WCO explanatory notes to CTH 8531 are fairly descriptive and restricted as to the type of "signaling" indicator panels and the like must perform in order to be classified under the heading. The EN 85.31 provides, in part: "these are used (e.g., in offices, hotels and factories) for calling personnel, indicating where a certain person or service is required, indicating whether a room is free or not. It includes: "This heading includes, inter alia: For Advance (D) Indicator panels and the like. These are used (e.g., in offices, hotels and factories) for calling personnel, indicating where a certain person or service is required, indicating whether a room is free or not. They include: * Room indicators. These are large panels with numbers corresponding to a number of rooms. * Number indicators. The signals appear as illuminated figures on the face of a small box; in some apparatus of this kind t....
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.... more appropriately classified under 8531 20 00 at eight-digit level. 3.21 It is further submitted that in term of Rule 1 of General Rules of Interpretation of the Harmonized System (GRI), the titles of Sections, Chapters and sub-chapters are provided for ease of reference only, for legal purposes, classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes and, provided such headings or Notes do not otherwise require, according to the provision stipulated therein. 3.22 Further, GRI Rule 3(a) states that the heading which provides the most specific description shall be preferred to headings providing a more general description. As stated above, it is undisputed that the subject goods are intended for use for display of volume & price of the fuel. Given that heading 8531 specifically encompasses "Electric sound or visual signaling apparatus," its application is most appropriate for categorizing the subject goods as "signaling apparatus" in accordance with GRI Rule 3(a). 3.23 In this regards reliance is placed on judgment of the Hon'ble Tribunal in the matter of M/s Diamond Electricals Ltd. Vs Commissioner of Custom....
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....ing distance, time, audio output, external temperature and RPM by lighting pre- designed letters, numbers, symbols and shapes in segmented formats. 3.27 Without prejudice to the submissions made above, it is submitted that the product under consideration is not categorically covered under tariff heading 8524 and are correctly classifiable under tariff heading 8531. 4. Port of Import and reply from jurisdictional Commissionerate: 4.1 The applicant in their CAAR-1 indicated that they intend to import the subject goods i.e. Indicator Panel Incorporating Liquid-Crystal Display (LCD) Screen, Decoder Integrated Circuit (IC) & Processor IC at the jurisdiction of Office of the Commissioner of Customs, Air Cargo Complex, Chennai. The application was forwarded to the Office of the Commissioner of Customs, Air Cargo Complex, Chennai for their comments on 21.01.2025. The concerned jurisdictional Commissionerate vide their letter dated 17.03.2025 has submitted as follows: ⮚ As per Chapter Note 7 to Chapter 85, it is evident that flat panel display modules which are equipped with components for converting video signals (e.g., a scaler IC, Decoder IC or application pro....
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....ereas the item under consideration are meant to display the signals processed by the microprocessor received from the fuel pump and other components of the dispenser, which are further decoded and displayed as the data related to fuel flow rate, volume and price etc., it is clear that the subject goods do not fall in any of the categories mentioned in the explanatory notes above and therefore they would not be covered under CTI 85312000. Thus, the contentions of the importer that the import goods merits classification under CTI 85312000 also appear incorrect. ⮚ Further, as the import goods are LCD modules equipped with a decoder IC and a Processor IC with permanently fixed back light, which displays the data from a particular machine (which in the present case is a fuel dispenser) shall be in terms of the Note 2(b) of Section XVI of the Customs Tariff Schedule II, would merit classification as parts of that machine. ⮚ To identify the correct classification of the import goods which are parts of a fuel dispenser it needs to see where a fuel dispenser would merit classification. In this regard, it pertinent to note that CTH 8413 covers pumps for liquid....
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....ange of pumps that are used to deliver liquids. HSN Explanatory Notes to this heading indicate that it covers a broad range of pumps with built-in or designed-to-be-integrated volumetric control mechanisms. These pumps can also perform various additional functions. It is also highlighted in the explanatory notes that if the measuring device is separate, both the pump and device should be classified separately. This heading also applies to pumps for fuel delivery, food processing, and other industries. ⮚ One can submit, for the sake of argument, though not admitted, that the indicator panel incorporating LCD display, decoder IC & processor IC can be considered as an integral 'part' of fuel dispensing pumps. As such, these components are intended for exclusive and principal use with fuel dispensing pumps. Hence the appropriate classification for the subject goods should be under tariff entry 8413 91 90 (i.e., Part: Other category). ⮚ However, in this regard, applicant would like to invite attention to the term of the Explanatory Notes to tariff heading 8413, parts specifically designed for use with pumps, such as pump housings or bodies, and co....
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....if any, and to confirm whether the product incorporates any input features-such as buttons or similar mechanisms-that allow the user to provide specific inputs. In response, vide email dated 22.05.2025, the applicant has submitted that the supplier describes the product as a fuel dispenser display board/display screen. It has been clarified that the product does not incorporate any touchscreen functionality. The applicant has further stated that the product under consideration does not have any input features-such as buttons, touchpads, or similar mechanisms-integrated within the LCD unit. The LCD is solely designed for display purposes and does not enable any form of user interaction or data entry. Any required user input is facilitated exclusively through an external keypad unit, which is separate from the LCD module. As such, the LCD does not support or allow input through touch, buttons, or any other interactive interface. Users are not able to transmit or enter information through the LCD in any manner. DISCUSSION AND FINDINGS 7.1 I have considered all the materials placed before me in respect of the subject goods. I have gone through the submissions made by the appli....
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....ments. 7.6 Before proceeding with the classification of these devices, it is essential to understand the nature of the subject goods, which have been described by the applicant as an Indicator Panel incorporating a Liquid Crystal Display (LCD) screen, Decoder Integrated Circuit (IC), and Processor IC. These panels are used in fuel dispensing pumps to display the volume and price of fuel dispensed, and they serve as a critical component of the fuel dispenser system. Based on publicly available information, the product described appears to be commonly referred to in the market as a fuel dispenser display board or display screen. There is no reference to the product being described as an "indicator panel," as claimed by the applicant. It is observed that the term "indicator panel" is not typically used for such products in commercial or technical contexts. Accordingly, the applicant was requested, vide email dated 29.04.2025, to clarify the basis for referring to the product as an "indicator panel." In response, vide email dated 22.05.2025, the applicant submitted that the supplier describes the product as a fuel dispenser display board/display screen. Therefore, it is evident t....
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.... the Customs Tariff Heading (CTH) 8413 covers "Pumps for liquids, whether or not fitted with a measuring device; liquid elevators". The relevant Customs Tariff entries to Heading 8413 is reproduced below for ease of reference: Headings/Sub- Headings /Tariff Item Tariff Description 8413 PUMPS FOR LIQUIDS, WHETHER OR NOT FITTED WITH A MEASURING DEVICE; LIQUID ELEVATORS - Pumps fitted or designed to be fitted with a measuring device: 8413 11 -- Pumps for dispensing fuel or lubricants, of the type used in filling stations or in garages: 8413 11 10 --- Hand pumps --- Other : 8413 11 91 ---- Pumps for dispensing fuel 8413 11 99 Other: 8413 19 -- Other 8413 19 10 --- Hand pumps 8413 19 90 --- Other 8413 20 00 - Hand pumps, other than those of sub-heading 8413 11 or 8413 19 841330 Fuel, lubricating or cooling medium pumps for internal combustion piston engines: 84133010 --- Injection pumps for diesel engines 84133020 --- Oil pump 84133030 --- Water pump 84133090 --- Other 84134....
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....eon, stipulates that classification of parts of machines of heading 8413 are: "Subject to the general provisions regarding the classification of parts (see the General Explanatory Note to Section XVI) ...... ". Further, it would also be useful to refer to Note 2 of Section XVI of the Customs Tariff Act, 1975 which provides for rules to be followed while classifying "parts of machines" falling under Chapters 84 and 85. The relevant part of the Section Note 2 is reproduced below: "2. Subject to Note I to this Section, Note 1 to Chapter 84 and 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, 8487, 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....
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....rocessor. Additionally, it excludes those modules that have assumed the character of goods of other headings. In the present case, the applicant has submitted that the product in question contains both a decoder IC and a processor IC, which work in conjunction to convert raw data (e.g., fuel volume and price) into a visually understandable display format. This functional aspect indicates that the module performs video signal processing and data conversion, and is not limited to merely receiving and displaying information. In light of these facts, it is evident that the product is excluded from the scope of Heading 8524. The presence of components such as the decoder IC and processor IC confers upon the product a character beyond that of a simple flat panel display module, as contemplated under Chapter Note 7. Accordingly, the product cannot be classified under Heading 8524. 7.10 The applicant has submitted that the product under consideration, namely, Fuel dispenser display boards/display screens (indicator panel as described by the applicant), is intended for use in displaying the volume and price of fuel. This indicates that the product functions as a visual signaling ap....
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....imes in which one or more metal tubes are struck, emitting a musical note or series of musical notes, and electrically operated church bells, other than carillons suitable for playing music (Chapter 92). Electric bells and door chimes are usually designed to be operated from a low tension supply (primary cell or battery), but in certain cases they incorporate a transformer to step down the mains voltage. (B) Electric sound signalling apparatus, horns, sirens, etc. The sound is produced by a vibrating reed, by a rotating disc set in motion electrically or electronic sound generator, they include factory sirens, air raid sirens, ships sirens, etc. (C) Other electrical signalling apparatus (winking or intermittent lights, etc.) for aircraft, ships, trains or other vehicles (other than for cycles or motor vehicles heading 85.12), but not radio or radar apparatus of heading 85.26. (D) Indicator panels and the like. These are used (e.g., in offices, hotels and factories) for calling personnel, indicating where a certain person or service is required, indicating whether a room is free or not. They include: (1) Room indicators. These are large p....
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.... include: (1) Apparatus operated by a fusible product (wax or special alloy) which melts when the temperature rises above a certain point, thus allowing electrical contacts to close and set off the alarm. (2) Apparatus based on the expansion of a bi-metal strip, liquid or gas expansion beyond a certain point operating the alarm. in one type, the expansion of a gas forces a piston to move in a cylinder; a valve is incorporated so that a slow expansion does not set off the alarm, but only a sudden expansion due to a sudden rise in temperature. (3) Apparatus based on the variation in the electrical resistance of an element subjected to a change in temperature. (4) Apparatus based on photoelectric cells. A ray of light is focussed on the cell and, if obscured to a predetermined extent by smoke, operates the alarm. Similar apparatus fitted with a graduated indicator or a recording system fall in Chapter 90. In addition to the automatic fire alarms, the heading also covers non-automatic alarms, such as are mounted in streets, for calling the fire brigade. (G) Electric vapour or gas alarms, consisting of a detector and a sound or visua....
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....ve as a signaling device, but to operate as a complex display interface forming part of a fuel dispensing system. Therefore, it cannot be classified as an electrical sound or visual signaling apparatus under Heading 8531. 7.10.2 Additionally, based on information from the public domain, the product is consistently referred to as a "fuel dispenser display board" or "display screen," and not as an "indicator panel," as claimed by the applicant. In commercial parlance, the name and intended use of a product play a crucial role in determining its classification. The absence of the term "indicator panel" in trade and marketing references indicates that the product is more accurately identified as a display module designed for integration into a larger machine (i.e., a fuel pump). Accordingly, as the product is clearly a part of a fuel dispenser rather than an independent signaling apparatus, classification under CTI 8531 20 00 is not appropriate. Further, Rule 3(a) of the General Rules for the Interpretation of the Import Tariff (GRI), which prioritizes classification by the most specific heading, is not applicable here because the product is not known or marketed as an indicator ....
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....ut Type Alphanumeric/graphic Light indicators (LEDs, lamps) Complexity More complex, often programmable Simple, often hardwired Interactivity May be interactive (touch) Not interactive Information Shown Values, messages, menus, etc. ON/OFF, fault status, basic signals 7.10.5 The applicant in support of their claim had placed reliance on the judgment of the Hon'ble Tribunal in the matter of M/s Diamond Electricals Ltd. Vs Commissioner of Customs, Chennai, 2012 (280) E.L.T. 137 (Tri. Chennai), wherein it was held that indicating panels with 4 zones incorporating LCD panel, CTEC indicating panel with LCD 1 Loop Apollo Protocol (Non- expandable) and Indicating Panel with LCD Repeater are classifiable under CTH 8531 20 00 of customs tariff act, 1975 as "Indicator panels incorporating liquid crystal devices or light emitting In this regard, it is important to note that the product under consideration in the present case, comprising an LCD display, decoder IC, and processor, is a component specifically and undoubtedly designed to be integrated into a fuel dispensing pump. This is materially different from the products examined in the cited judgme....
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....in specified Chapter Heading, are in all cases to be classified in their respective headings as per Note 2(a) of the Customs Tariff Act, 1975. Thus, there is a condition to classify any part in its respective heading that it should be goods which is included in any heading of Chapter 84 or 85 which means it should be clearly listed in Chanter 84 or 85. However, as discussed above the impugned goods i.e. " Display module for fuel pump" are not included in any of the headings of Chapter 84 or 85 and hence could not be classified as per above Note 2(a). 7.11.2 I observe that the Display Module equipped with an LCD screen, decoder IC, and processor IC, plays a crucial role in converting raw operational data (such as the volume and price of dispensed fuel) into a human-readable visual format. This functionality is essential for displaying information to the user in a fuel dispensing system to ensure accuracy and transparency in the fuel transaction. These display modules are specifically designed to be used as integral parts of fuel pumps. Further, Note 2(b) to Section XVI, applies only in cases where such parts cannot be classified as per Section Note 2 (a). In this case, the Displa....