TaxTMI 
TaxTMI 
2025 (1) TMI 1716
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....dated 16.07.2024 has submitted as follows: 2.1 M/s. Apple India Private Limited, India ('Applicant'), is a company having its registered head office located at 13th Floor, Prestige Minsk Square, Municipal No. 6, Cubbon Road, Bengaluru, Karnataka. The Applicant is a company incorporated under the Companies Act, 2013 and is engaged in the business of importing electronic consumer goods under the brand name 'Apple' such as iPhones, iPads, iPods, Mac Book (laptops) and computers for selling the same in India through online sales portal, channel partners and distributors located in India. 2.2 The Applicant in furtherance to its current business is proposing to engage in import of 'Apple Vision Pro' into India. The kitted accessories of Apple Vision Pro namely Dual Loop Band, Solo Knit Band, and Light Seal [kitted accessories] shall be imported by the applicant on standalone basis. Overview of Apple Vision Pro 2.3 Apple Vision Pro hereinafter referred to as the 'device', is designed to be worn on the user's head and acts as a spatial portable automatic data processing machine. The devices functions as an independent spatial computing machin....
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....ce, i.e., Apple Vision Pro as mentioned below: a) Apple Vision Pro (HMD) b) Light Seal Cushions c) Battery d) Cover e) 30W USB-C power adaptor f) USB-C Charge Cable 2.9 The Apple vision pro along with the listed accessories will be imported in a consolidated pretty white box under a one single invoice, where a consolidated/single price is charged for the unit, i.e., the device and the accessories. Further, the specified accessories, namely, light seal, solo knit band and dual loop band (together referred to as 'kitted accessories') shall be imported by the Applicant on a standalone basis. The Apple Vision Pro and its accessories (imported in the pretty white box) and the kitted accessories (imported on a standalone basis) shall be assembled at the brick-and-mortar retail store and sold to customers as a single unit (i.e., Apple Vision Pro) for a consolidated/single price. Overview of the kitted accessories (Dual Loop Band, Solo Knit Band and Light Seal) which are imported on a standalone basis 2.10 The accessories imported by the Applicant, namely the Dual Loop Band, Solo Knit Band, and Light Seal are specifical....
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....ple Vision Pro body. For ease of reference an image of the Light Seal has been re-produced as follows- 2.11 Thus, in view of the above overview, the aforementioned products augment the Apple Vision Pro's user experience by improving the overall usability of products. Applicant's interpretation of Law/Facts 3.1 The Applicant submitted that the kitted accessories namely Dual Loop Band, Solo Knit Band, and Light Seal shall be imported on a standalone basis. The classification of each of the kitted accessory are analysed as under: Analysis of classification of Dual Loop Band under CTH 8473 3.2 In the present case, since the Dual Loop Band is to be used with Apple Vision Pro which is essentially an Automatic Data Processing Machine and is classifiable under CTH 8471, reference must be made to CTH 8473 which covers "Parts and Accessories" of products covered under CTH 8470, CTH 8471 or CTH 8472. 3.3 Here it becomes pertinent to discuss the scope CTH 8473 which inter alia covers "parts and accessories" which are solely and principally used with products covered under CTH 8471. 3.4 The term "parts" or "accessories" has not been defined in the Customs Tariff, th....
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....ther, the term "accessory" includes those products which perform a particular function to increase its range of operations or perform a particular service relative to the main function of the products. 3.9 In the present case, the Dual Loop Band is a specialized product for use with Apple Vision Pro. It is designed to secure or hold the Apple Vision Pro in place comfortably. The Dual Loop Band features a pair of upper and lower straps which are interconnected with each other through a joint. The Dual Loop Band attaches to the Audio Straps of Apple Vision Pro with a simple and secure mechanism, and release tabs which allow the user to quickly detach it when needed. 3.10 Based on the preceding description of the Dual Loop Band, it is understood that the Dual Loop Band is used to enhance the functionality and application of the Apple Vision Pro and is solely used with Apple Vision Pro. By securely fastening the Apple Vision Pro to the user's head, the Dual Loop Band significantly enhances the user experience by improving the overall usability of the product. 3.11 Further, the Dual Loop Band can only be used along with Apple Vision Pro and is not compatible with any other ....
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....ly detach it when needed. 3.17 Based on the preceding description of the Solo Kinit Band, it is understood that the Solo Knit Band is used to enhance the functionality and application of the Apple Vision Pro. Similar to the Dual Loop Band, the Solo Knit Band also helps in fastening of Apple Vision Pro to the user's head, thereby enhancing the user experience by improving the overall usability of the product. 3.18 Here it is also pertinent to mention that the Solo Knit Band can only be used along with Apple Vision Pro and is not compatible with any other electronic device. In order to support this fact, reference may be made to Apple online store wherein in the dropdown option for compatibility of Solo Knit Band it has been stated that it is compatible with Apple Vision Pro and no other device has been mentioned therein. 3.19 Thus, it can be said that the Solo Knit Band adds to the convenience and effectiveness of the Apple Vision Pro. Therefore, it fulfils the definition of the term "accessory" as defined earlier. Further, as the Solo Knit Band is used solely and principally with the Apple Vision Pro, thus it also fulfils the requirement of an accessory to be classifie....
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....y be made to Apple online store wherein in the dropdown option for compatibility of Light Seal it has been stated that it is compatible with Apple Vision Pro and no other device has been mentioned therein. 3.25 Thus, it can be said that the Light Seal adds to the convenience and effectiveness of the Apple Vision Pro. Therefore, it fulfils the definition of the term "accessory" as defined earlier. Further, as the Light Seal is used solely and principally with the Apple Vision Pro, it also fulfils the requirement of an accessory to be classified under CTH 8473, in terms of HSN Explanatory Notes to CTH 8473 3.26 As stated above, the Light Seal is a tailor-made product which is designed specifically for use with Apple Vision Pro. It is made up of stainless steel. thermoplastic elastomer, (which is painted with polyurethane), polycarbonate polyester, (Nickel & PVD coated) and is covered with polyester and nylon yarn for an aesthetic defined finish. It also comprises of a narrow woven elastomeric band which is placed for support of the nose of the user. Due to its composite nature and the absence of any single material that predominantly defines its essential character, the Light S....
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....f Customs, Air Cargo, Mumbai. The application was forwarded to the Office of the Commissioner of Customs, Air Cargo, Mumbai for their comments on 31.07.2024 & 23.10.2024. The concerned Commissionerate vide their letter dated 24.10.2024 has submitted as follows: ⮚ VR headsets are display devices and are classifiable under CTH 8528 as display devices that may utilize wireless transmission protocol to display data from an automatic data processing machine of heading 8471. ⮚ The device "Apple vision Pro" is a similar one as it can also be configured by pairing with Apple products such as iPhone, iPad and Mac or other ADPM of brand "Apple". However, over and above acting as a display device, "Apple vision Pro" can also process data and functions as an ADPM, as claimed by the applicant. Even after qualifying as an ADPM, the "Apple vision Pro" shares its physical characteristics with any other similar VR headset available in open market. ⮚ Physical constraints alone do not necessarily determine whether an item is considered "solely and principally" a part of a specific product. While a design may be unique when first created, its di....
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....fering benefits such as high- quality fabric, cushioning, breathability, aesthetic finish, and a tight seal to prevent light from leaking. ⮚ However, it is important to note that these accessories do not contribute to the fundamental functionality of the Apple Vision Pro. The eligibility of the Apple Vision Pro for classification as an Automatic Data Processing Machine (ADPM) is based on its core functions, not on its physical design or characteristics. Prima facie, it may appear that classification under CTH 8471 is appropriate due to its operational capabilities. ⮚ Therefore, as far as the compatibility of the items "Dual loop band", "Solo knit band" and "Light Seal" matters, these item are equally compatible with any VR headset" having similar specification and the "VR headset" are classifiable under CTH 8528. Therefore, cannot be treated as parts and accessories suitable for use "solely or principally" for machines of heading 8470 to 8472. ⮚ The item in question neither enhances functionality nor does application rather just enhance user experience which is different from user to user. On one side some user may find it comfortable....
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....ion. Thus, the claim for classification under 8473 should be rejected, and the classification should be adjusted to reflect the actual constituent materials involved. ⮚ Based on the discussion above, it is evident that the item in question cannot be classified under 8473. The physical properties and specifications of the Apple Vision Pro resemble those of VR headsets, which classified under 8528. If the applicant's claims are deemed factual, then it can also be considered a part or accessory of a VR headset, which would classify it under 8529. If the said items are not classified under 8529 then it will be classified as per their actual constituent materials involved. Details of Hearing 5.1 A hearing was held on 21.10.2024 at 03.00 PM. Shri. Gautam Khattar, Shri Anurag Sehgal and Shri Jimit Gandhi, authorized representative on behalf of the applicant appeared for the hearing and reiterated the contention submitted with the application. They submitted that the subject goods i.e. kitted accessories of Apple Vision Pro namely Dual Loop Band, Solo Knit Band and Light Seal will merit classification under CTI 84733099. They contended that as per Note 3(b) of GRI....
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....--- Other ---- Other), in terms of GIR I read with HSN Explanatory Notes to CTH 8473. Before deciding the classification of the kitted accessories namely Dual Loop Band, Solo Knit Band, and Light Seal, there is a need to examine the classification of the Apple Vision Pro as automatic data processing machine under CTH 8471 as claimed by the applicant. 6.3.2 From the submissions of the applicant, and the information available on the webpage of M/s. Apple, it appears that the Apple Vision Pro, have the following features, i.e., a pair of micro- OLED displays deliver more pixels than a 4K TV, VisionOS Operating System 8-core CPU with 4 performance cores and 4 efficiency cores, M2 Chip, RI Processor for real-time sensor input processing, Wi-Fi connectivity, Bluetooth connectivity, 3D camera, 256 GB, 512 GB & 1 TB internal storage, real time sensor, among others. These devices weigh 600 to 650 grams and runs on rechargeable batteries having a battery life of 2 hours for general use. These devices can process data, execute programmes, and connect to internet via a wireless network, send/receive e-mails, upload/download files, download software applications, conduct video/VOIP {voice ov....
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....oice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network); (iii) loudspeakers and microphones; (iv) television cameras, digital cameras and video camera recorders; (v) monitors and projectors, not incorporating television reception apparatus. (E) Machines incorporating or working in conjunction with an automatic data processing machine and performing a specific function other than data processing are to be classified in the headings appropriate to their respective functions or, failing that, in residual headings." 6.3.4 Therefore, there is a need to examine whether the features and specifications of Apple Vision Pro meet the criteria as laid down in the relevant Chapter Note reproduced above. For any device to be held as an ADP and classifiable under sub-heading 847130, four essential conditions as mentioned above in Note 6(A), are required to be satisfied. Let's break down and explain each of the four conditions one by one, with clarity and detail in the context of this device: a). Storing the processing program or programs and at least the data immedia....
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....rther, the goods also have an OPS slot. With the use of the OPS Slot, additional hardware can be connected to the goods and the OPS Slot can also be used for installing other operating software such as Windows, etc. on the goods. Thus, the goods are machines on which the user is able to load and execute a program. In other words, the goods are capable of executing any application/program which is stored on its memory. A user can, with the use of either Android or other operating systems, download and install new programmes in accordance with their needs and usage. Thus, goods are machines which can be freely programmed in accordance with the need of the user and hence, satisfy condition (ii) of Chapter Note 5(A) to Chapter 84." I also draw attention to Note 5 to Chapter 85 which stipulates that "For the purposes of heading 85.17, the term "smartphones" means telephones for cellular networks, equipped with a mobile operating system designed to perform the functions of an automatic data processing machine such as downloading and running multiple applications simultaneously, including third- party applications, and whether or not integrating other features such as digital cameras a....
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.... program's execution in real time, based on its sensors and the environment. 6.3.5 From the above, it can be concluded that the Apple Vision Pro is equipped with the necessary hardware, including sufficient RAM and storage, to support the storage and execution of its operating system and software programs, enabling effective data processing. The software loaded onto the device is freely programmable, allowing users to customize the functionality according to their specific requirements. The device is capable of performing the arithmetical computations as specified by the user, and its processing program enables it to modify its execution dynamically based on logical decisions during the processing run without human intervention. In light of these capabilities, the Apple Vision Pro meets all the criteria outlined in Note 6(A) of Chapter 84, thereby qualifying it as a device covered by the definition of automatic data processing machine (ADPM). 6.3.6 Further, HSN Explanatory Notes to CTH 8471 further elucidates on what constitutes an Automatic Data Processing Machine (ADPM). The relevant portion of the Explanatory Notes are extracted below: "(1) AUTOMATIC DATA PROCESSING....
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....se a number of such fixed programs. These machines have storage capability and also stored programs which can be changed from job to job. Automatic data processing machines process data in coded form. A code consists of a finite set of characters (binary code, standard six bit ISO code, etc.). The data input is usually automatic, by the use of data media such as magnetic tapes, or by direct reading of original documents, etc. There may also be arrangements for manual input by means of keyboards or the input may be furnished directly by certain instruments (e.g., measuring instruments). The input data are converted by the input units into signals which can be used by the machine, and stored in the storage units. Part of the data and program or programs may be temporarily stored in auxiliary storage units such as those using magnetic discs, magnetic tapes, etc. But these automatic data processing machines must have a main storage capability which is directly accessible for the execution of a particular program and which has a capacity at least sufficient to store those parts of the processing and translating programs and the data immediately necess....
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....arrive at a decision regarding the eligibility or otherwise of the claimed classification, it is of paramount importance to ascertain whether the subject goods is a machine performing any principal function other than data processing. 6.3.9 Thus, irrespective of the fact that the product i.e. Apple Vision Pro marketed by the applicant as Spatial Computer, would merit classification under Heading 8471 only if the conditions as stipulated and discussed supra are adhered to. The rules of interpretation for classification, Section Notes and Chapter Notes as specified under Customs Tariff Act 1975 are applicable for classification of the impugned goods. It would not be out of place to mention here that Chapter Note 6 (E) of Chapter 84 stipulates that machine performing a specific function other than data processing merits classification in appropriate headings/residual headings. Thus, any primary functionality other than data processing would disentitle the Apple Vision Pro from getting classified under heading 8471 ibid. 6.3.10 From the submissions of the applicant, and the information available on the webpage of M/s. Apple, it appears that the Apple Vision Pro can process dat....
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....cessing merits classification in appropriate headings /residual headings. In the instant case, these devices have computing and communication capabilities. However, for the product under consideration, automatic data processing appears to be the main function. while other functionalities of said machine are not different from auxiliary functions that could be seen on any computer, such as desktop or laptop computers. In Circular No. 20/2013- Cus, dated 14.05.2013, clarification has been given by the Board regarding the classification of "tablet computers" under heading 8471 stating that, " ... The mobile phone calling function could be provided by the products only as a supplementary function because it could not be activated without running an operating system of the devices .... These devices are not intended to be a substitute for a mobile phone to make voice calls, but, according to its main technical features is designed as a substitute for laptops. The difference between a "smartphone" and "tablet computer", is not based on whether the product has a voice calling function or not, but on the principal features that a producer has intended for the device when designing an....
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....y, to fall within the ambit of the above Note, the goods necessarily have to be such video game consoles/machines as defined above. Further, Chapter Heading 9504 includes machines besides video game consoles, which can be automatic data processing machines. However, as per technical specification of the product, the impugned goods are neither 'video game consoles' nor 'video game machines', but are an entirely different product which, though have gaming capabilities, are also having a wide array of functionalities such as internet surfing, multimedia playing, watching videos, computing, voice calling etc., and can be put to multiple uses. Considering the above information and details, the impugned goods satisfy the condition of Note 6(A) to Chapter 84 but does not fall under the purview of the Explanatory Note 2 to Chapter Heading 9504 as game consoles/game machine as they are not principally designed for entertainment purposes including playing games. Further, I also relied upon on the case of M/s. Asus India Private Limited vs. Commissioner of Customs, ACC, Chennai[ (2023) 11 Centax 85 (Tri .- Mad)], wherein the Hon'ble CESTAT, Chennai held that the g....
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.... the tablet computer has same functionality as a laptop as the same can process data, execute programs and connect to the Internet via a wireless network in order to, for example, exchange and manage e- mails, exchange or download files, download software applications, conduct video or VoIP communication, apart from being connected to a cellular network to make calls. In other words, automatic data processing is the main functionality, while other features are auxiliary in nature. Therefore, the tablet computer shall be classifiable under HSN 8471 30, which is the same classification used for laptops. In the present case, the primary functionality of the Apple Vision Pro is similar to that of a tablet or laptop, as it performs automatic data processing. Although it offers additional features like immersive AR/VR experiences, these are auxiliary features that do not change the device's core purpose as a computing device. Based on this reasoning, and in line with the CBEC Circular, the Apple Vision Pro can be considered similar to tablet computers and laptops for classification purposes. 6.3.16 I have also relied on the Advance Tariff Ruling dated 15.08.2024 (Ruling referen....
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....atial computing uses a 3D environment as the primary computing platform rather than the traditional 2D Graphical User Interface (GUI). This environment can be a virtual or augmented reality, where the user can interact with digital objects and information in a 3D space. It allows for natural and intuitive interaction, such as gestures, body language, and spatial awareness. These interfaces are designed to be human-like and can naturally interact with the world around them instead of using a mouse and a keyboard. As per the research paper on "Spatial Computing: Concept, Applications, Challenges and Future Directions" cited as arXiv:2402.07912 [cs.HC] and submitted on 30.01.2024, it is submitted that over the years, User Interfaces (UIs) have seen constant development and improvement. Command line interfaces. which have been around since the 1960s, require users to type in commands in order to interact with computers. In the 1980s, graphical user interfaces were developed to make computers more user-friendly. These interfaces used windows and icons to represent commands and data. In the 1990s, as the internet grew in popularity, web-based interfaces replaced traditional methods. T....
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....rgely confined to 2D displays. However, despite these technological differences, the Apple Vision Pro should still be classified as a portable computer (automatic data processing machine), as it performs the principal function of computing and data processing. It is observed that with advancement in the technology, the efficiency and performance of the products are bound to go up and the law requires that the tariff entries are to be interpreted in line with the technological advancement. The Hon'ble Supreme Court in the case of Collector of Customs & Central Excise v. Lekhraj Jessumal & Sons [1996 (82) E.L.T. 162 (SC)] as held that words in the traffic schedule need to be interpreted by considering the rapid development of technology as the industry cannot be static. The Hon'ble Supreme Court held as follows: "3. The High Court in the impugned order noted that the stand of the Customs authorities was that the words "switches, miniaturised" as component parts of hearing aids should be understood to mean only those types of switches which were generally used in the manufacture of hearing aids at the time of publication of the Import Policy for the relevant year, ....
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.... that the Apple Vision Pro is a portable computer, as it performs the essential function of computing and data processing. The product's additional features, such as the 3D User Interface, voice command, eye tracking and gestures movement etc., are nothing but technological advancement due to which the Apple Vision Pro cannot be made fall under any other tariff entry. 6.3.21 As discussed above, it is clear that the Apple Vision Pro, having the primary function of automatic data processing, fall within the scope of Chapter Heading 8471 (Automatic data- processing machines and units thereof, magnetic or optical readers, machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included), in accordance with Chapter Note 6(A) to Chapter 84 and Explanatory Notes to CTH 8471. 6.4 Now, I take up the matter of classification of the kitted accessories namely Dual Loop Band, Solo Knit Band and Light Seal for Apple Vision Pro under CTH 8473 (Parts and accessories (other than cover, carrying cases and the like) suitable for use solely or principally with machines of headings 8470 to 8472) as claimed by the applicant....
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....omponent of the whole, without which the whole cannot function." On the other hand, the term "accessory" was defined as something "supplementary or subordinate in nature, which is not essential for the actual functioning of the product". Furthermore, the Hon'ble High Court of Delhi, in the case of Vodafone Mobile Services Limited Vs. Commissioner of S.T., Delhi, [2019 (27) G.S.T.L. 481 (Del.)], defined the term "accessory" as an "article or device that adds to the convenience or effectiveness of but not essential to the main machinery". According to Chapter 11 (Definitions) of the Foreign Trade Policy (FTP) 2023, "Accessory" or "Attachment" means apart, sub-assembly or assembly that contributes to efficiency or effectiveness of a piece of equipment without changing its basic functions. In light of the above, it can be understood that a "part" is a component of equipment or machinery that is essential to its functioning. In other words, a "part" is an integral element of the machinery or equipment, without which the product cannot operate. On the other hand, an "accessory" is something that enhances the convenience or effectiveness of the machine, but it does not contri....
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....ease its range of operations or perform a particular service relative to the main function of the products. In the context of CTH 8473, this means that if an accessory is deemed to be primarily intended for use with machines classified under CTH 8470 to 8472, it must be designed to function primarily with those machines, and not with others outside of this category. The accessory's design, function, and purpose must align with the specifications of the machines covered by those tariff headings. In the present case, the Dual Loop Band, Solo Knit Band, and Light Seal are designed with specific features, characteristics, and functions that make them suitable only for use with the Apple Vision Pro. Their design, material properties, and purpose are all tailored to complement the Apple Vision Pro's features, enhancing user comfort, fit, and usability. These accessories, by their very nature, are not meant to serve any other purpose outside of their association with the Apple Vision Pro. For example, the Dual Loop Band and Solo Knit Band are crafted to fit securely around the Apple Vision Pro and adjust according to the user's head shape, ensuring a comfortable fit duri....
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.... -- Of the electronic calculating machines of sub-heading 8470 10, 8470 21 or 8471 29 8473 29 00 Other 8473 30 - Parts and accessories of the machines of heading 8471: 8473 30 10 Microprocessors 8473 30 20 Motherboards 8473 30 30 --- Other mounted printed circuit boards 8473 30 40 --- Head stack --- Other : 8473 30 91 ---- Network access controllers 8473 30 92 ---- Graphic and intelligence based script technology (GIST) cards for multilingual computers 8473 30 99 -- Other 8473 40 - Parts and accessories of the machines of heading 8472: 8473 40 10 --- Parts of duplicating, hectograph or stencil machines 8473 40 90 Other 8473 50 00 - Parts and accessories equally suitable for use with the machines of two or more of the heading 8470 to 8472 On perusal of the above entries, it is clear that the single dash (-) entry 8473 30 covers "Parts and accessories of the machines of heading 8471" which is further sub-divided. Further, under the CTSH 847330, there is no specific entry at the eight-digit level which co....
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....mmissioner of Customs (Import), New Delhi [Final Order Nos. 50076-50077 of 2022 in Appeal Nos. C/50708-50709/2021, decided on 2-2-2022] wherein the Hon'ble CESTAT Delhi while deciding the classification of Interactive Display System held that the same would be classified under Tariff heading 8471 as an automatic data processing machine since it satisfies the test for an ADP machine under the said heading prescribed under Note 5(A) to Chapter 84 by application of GRI 1. In the instant case, the Hon'ble Tribunal also held that the mere presence of a large screen could not imply that the subject goods are classifiable as monitors under CTH 8528, if these goods are otherwise capable of performing a function of ADP machine under Tariff heading 8471. In view of the above, it is clear that these items are accessories to the Apple Vision Pro, which is classified under CTH 8471. Therefore, I find no merit in classifying these accessories under CTH 8529 (Parts suitable for use solely or principally with the apparatus of headings 8524 to 8528), as proposed by the concerned commissionerate. 7.2 Further, I find that the concerned commissionerate proposed that if the said items are....