TaxTMI 
TaxTMI 
2026 (1) TMI 1494
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....untries such as China, Japan, Taiwan, Hong Kong, Indonesia, Malaysia etc. - reg. 2. Submission by Applicant The applicant has informed that M/s Manuel Steel Decor (IEC: EKYPS6567Q) intends to commence a business of import and sale of Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes with or without drilled hole in corner' in India. The item and its utility are given below: 2.1 Item & its utility: 2.1.1 Background - In the present matter, the applicant, M/s Manuel Steel Decor intends to import the Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes with or without drilled hole in corner' in different consignments from a few foreign countries such as China. Japan. Taiwan, Hong Kong. Indonesia. Malaysia etc. 2.1.2 Features: The said goods are - i) "Architectural Decorative Designer Wall Panel Articles of Stainless Steel in various shapes, sizes, and surface finishes with or without drilled holes in the corners, are fully manufactured and dimensioned products. These panels may be surface-finished. Multi - dimensional, multi-coloured, or PVD (....
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....ding 73089090 or 73269060 under the Customs Tariff Act. 1975. 2.1.3 Core functions/utility of the said goods: These 'Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes' are intended for various architectural/structural and decorative applications. Some core functions/utility of the said "Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes" are listed below: a) Facade Cladding Systems: Installed as external wall cladding on high-rise buildings. commercial towers, airports, hotels, shopping malls, and institutional buildings. These 'Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes. sizes and finishes' are mechanically fixed or structurally bonded onto façade sub-frames or vertical grid systems using concealed brackets, rivets, or structural adhesives. Once installed. they protect the building envelope, provide weather resistance, and create a modern architectural appearance. Remain permanently in position and are designed to withstand wind loads, thermal expansion, and other structural stresses. ....
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....rength and design appeal. These 'Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes are permanently bonded or mechanically fastened to the subfloor. h) Architectural Elements in Transportation Infrastructure: Deployed as permanent wall panels, roof panels, ceiling covers, and feature screens in metro stations, railway concourses, airport terminals, bus depots, and passenger waiting halls. These 'Architectural Decorative Designer Wall Panel Article of Stainless Steel of different shapes, sizes and finishes' provide durability, vandal resistance, easy cleaning, and fire safety and these are fixed mechanically for decades-long service life as a structural part of the built infrastructure i) Elevator infrastructure: These. Architectural Decorative. Designer Wail Panel Article of Stainless Steel of different shapes, sizes and finishes, when installed in elevator shafts and cabins ensures the vertical guidance of the elevator car and counterweight, thereby simplifying integration of elevators in new constructions without heavy structural modifications, ensure a smooth. vibration-free ride, ensure the structura....
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....ant has also submitted that - As per the General Note '(IV) Production of finished products' of the World Customs Organization Harmonized Commodity Description and Coding System Explanatory Notes the finished products may be subjected to further finishing treatments or converted into other articles by a series of operations like Mechanical Working i.e. perforation and punching etc. and Surface Treatments or other operations including cladding, coating or polishing etc., to improve the properties or appearance of the metal, protect it against rusting and corrosion etc. The relevant portion of the WCO Explanatory notes is reproduced below: "(C) Subsequent manufacture and finishing The finished products may be subjected to further finishing treatments or converted into other articles by a series of operations such as: (1) Mechanical working, i.e., turning, milling, grinding, perforation or punching, folding, sizing, peeling. etc .; however, it should be noted that rough turning merely to eliminate the oxidation scale and crust and rough trimming are not regarded as finishing operations leading to a change in classification. (2) Surface trea....
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....d rouge). Final polishing reaches a reflectivity rating of approximately 8000 grit equivalence - hence the term '8K'. * Machinery Used: Automatic or semi-automatic polishing lines, rotary buffers, felt wheels with buffing compounds, clean-room polishing setups for premium output. Result: Produces a high-gloss, mirror-like finish suitable for decorative panels. premium interiors, or architectural features where maximum reflectivity is desired. ii) 10K Mirror Finish: * Base Material: Mill finish, semi-finished flat rolled stainless steel material. * Technical Process: Similar multi-stage polishing as 8K but with additional ultra-fine finishing. Uses micro-grit compounds (sub-micron size) and extra buffing passes under clean- room conditions to remove any micro-scratches or swirl marks. * Machinery Used: High-speed, precision buffing units with micro-fiber polishing pads: controlled environment for final pass to avoid contamination. Result: Yields an ultra-premium, highly reflective finish surpassing the standard 8K. producing a near-flawless mirror surface used for luxury facades, lift cabins, or designer interiors. ....
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....-finished flat rolled stainless steel material. * Technical Process: The surface is blasted with fine abrasive media (e.g., silica sand, aluminium oxide) using compressed air or suction blasting. Typical blasting pressure ranges from 3 to 6 bar with controlled nozzle distance for uniform texture. * Machinery Used: Closed-cabinet or open-cabinet sandblasting equipment with dust collection. Result: Produces a matte, grainy texture that diffuses light reflection and provides anti- slip properties; used for exterior cladding or artistic panels. viii) Water Repellent Finish: * Base Material: Mill finish, semi-finished flat rolled stainless steel material. * Technical Process: Application of hydrophobic nano-coating or fluoropolymer-based spray that chemically bonds to the stainless-steel surface, creating a contact angle that causes water to bead and roll off. * Machinery Used: Spray booth or roll-coating equipment with UV or thermal curing where required. Result: Prevents water spots and facilitates easy cleaning, ideal for facades, signage, and exterior architectural panels. ix) Linen Finish: * B....
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....ching lines with precise resist application and acid circulation tanks. Result: Produces detailed, permanent patterns used for branding, decorative facades, and custom architectural panels. xiv) Embossed Designs: * Base Material: Mill finish, semi-finished flat rolled stainless steel material * Technical Process: The panel is fed through matched rollers or a press die which imprints raised or recessed patterns on the metal. * Machinery Used: Heavy-duty embossing presses or pattern roller mills. Result: Adds 3D texture for both visual and functional effect (e.g., slip resistance, visual branding); common in decorative ceilings and wall panels. xv) PVD Coating (Physical Vapour Deposition): * Base Material: Mill finish, semi-finished flat rolled stainless steel material. * Technical Process: The panel is cleaned and placed in a vacuum chamber where metal vapours (e.g., titanium nitride) are ionized and bonded to the stainless steel at high temperatures, forming a hard, coloured layer. * Machinery Used: High-vacuum PVD chambers with magnetron sputtering or arc evaporation. Result: Provide....
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.... Surface Processing and Finishing ("Further Worked" condition): a) After cutting, the panels undergo a range of advanced surface finishing operations to impart distinct aesthetic and functional characteristics. b) These finishes not only enhance appearance but also modify performance attributes such as reflectivity, scratch resistance, texture, and anti-fingerprint properties. c) Once processed. the panels are no longer semi-finished products but finished stainless- steel articles, directly usable in architectural, decorative, or structural applications. iv) Detailed Technical Description of Surface Finishes: All finishes are carried out exclusively on cut-to-size panels prepared from mill finish flat rolled stainless steel materials (i.e., "further worked" condition transforming base material into finished stainless-steel articles. The detailed types of finishes have already enumerated above. v) Protective Treatment (After "Further Worked" conditions are satisfied): After finishing, panels are laminated with protective PVC films (3C. 5C, 7C microns) to prevent scratches, abrasions, or environmental damage during transp....
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....ch as wall cladding, elevator interiors, ceilings, furniture elements, partitions, or decorative facades) do not necessarily require mounting holes, as they are often fixed using alternative methods, such as: * Adhesive Bonding - Using high-strength industrial adhesives, epoxy resins, or construction- grade double-sided tapes. * Hook-On / Clip-On Systems - Panels are slotted into concealed mounting clips or rails, giving a seamless finish. * Channel or Frame Inserts - Panels are set into aluminium/steel channels, providing structural support without drilling. * Magnetic or Velcro Fixing Systems - Used for lightweight decorative panels requiring removability. In such applications, the panels are independent finished decorative articles of stainless steel, which are appropriately covered under HS Code 73269060 (Other articles of stainless steel). These panels, by virtue of cutting, finishing, optional Physical Vapor Deposition (PVD) coating. optional mounting provisions, and dimensional specification. are complete finished products and these are used as structural parts or decorative articles. Therefore, these goods are appropriately class....
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....osed to be imported, described as "Architectural Decorative Designer Wali Panel Articles of Stainless Steel of different shapes, sizes and finishes with or without drilled holes in corners", are classifiable under Customs Tariff Heading 7308 90 90 or 7326 90 60, as claimed by the Applicant, or under other Customs Tariff Heading under CTH 7219 for example under CTH 7219 90 90 of the First Schedule to the Customs Tariff Act, 1975." 6.3 I observe that the Applicant has restricted the question for advance ruling to classification under Headings 7308 and 7326. However, it is a settled position of law that the Authority for Advance Rulings is not bound by the tariff headings suggested by the Applicant and is required to determine the correct classification in accordance with the Customs Tariff Act. 1975, the General Rules for Interpretation and existing legal positions in terms of relevant case laws. 6.4 On examination of the records, I find that the subject goods are manufactured from flat- rolled stainless-steel sheets. These sheets are cold-rolled and thereafter subjected to cutting to size and various surface finishing processes such as mirror polishing, hairline finish, satin ....
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....rties or appearance of the metal, protect it against rusting or corrosion, etc." The Explanatory Notes further clarify that such finishing operations do not affect classification so long as the products retain the character of flat-rolled products. 6.7 I find that the various surface finishing processes applied to the subject goods. including mirror polishing, embossing, etching, PVD coating, anti-fingerprint coating and PVC lamination, merely enhance their appearance, corrosion resistance and durability. These processes do not bring into existence a new product having a distinct name, character or use. nor do they alter the fundamental identity of the goods as flat-rolled stainless-steel products. The applicant has claimed that the subject goods provide weather resistance and create a modern architectural decorative appearance. This legal position stands fortified by judicial precedents. In Zaverchand Gaekwad Pvt. Ltd. V/s Union of India [1992 (61) E.L.T. 225 (Guj.)], the Hon'ble Gujarat High Court held that galvanisation of steel does not amount to manufacture, as the basic character of steel remains unchanged. Similarly, the Hon'ble Supreme Court, in the matter of Me....