TaxTMI 
TaxTMI 
2026 (2) TMI 1027
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....Left Hand (or RAIL FR LH) are used for manufacturing of car window regulator assembly and it provides a guided path for the window glass, supports the regulator mechanism, and ensures smooth, stable, and quiet operation of the window system on the front-left side of the vehicle. RAIL FR LH are small rollers or sliders that reduce friction in guide rails and used in engineering applications in car window regulators. These parts are integral to systems that require smooth, controlled, and low-friction movement. Window Regulator Guide Rail, also referred as Rail Frame Left Hand (RAIL FR LH) is covered under the HSN Code 84799090. 2.2 The Applicant submitted that HSN Code 8479 explains MACHINES AND MECHANICAL APPLIANCES HAVING INDIVIDUAL FUNCTIONS, NOT SPECIFIED OR INCLUDED ELSEWHERE IN THIS CHAPTER. Accordingly, as per the rules and notes of the Customs Tariff Act, standalone mechanical functions not specified elsewhere shall fall under 8479. The goods sought for Advance Ruling are parts of HSN Code 8479 that is 8479 9090. Since the articles of Tariff Heading 84.81 are specifically excluded from Section XVII vide Section Note 2(e) of the Customs Tariff Act, 1975 are not covered und....
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....ting fittings and parts thereof of heading 9405; or (1) brushes of a kind used as parts of vehicles (heading 9603). Since the articles of Tariff Heading 8479 are specifically excluded from Section XVII vide Section Note 2(e) of the Customs Tariff Act, 1975, on this ground also the product 'RAIL FR LH cannot be considered to be part of the vehicle for the purpose of classification. They relied on 2019 (31) G.S.T.L. 359 (A.A.R. - GST)- BEFORE THE AUTHORITY FOR ADVANCE RULING UNDER GST, KARNATAKA Shri Harish Dharnia, Member (Central Tax) and Dr. Ravi Prasad M.P., Member (State Tax) IN RE: SAGAS AUTOTEC PVT. LTD. Advance Ruling No. KAR ADRG 90/2019, dated 26-9-2019 LPG conversion kit for automobiles - Classification - Rate of GST- said item consisting of various parts, is an apparatus for providing alternate fuel to internal combustion engines of vehicle - In instant case said kit is specific to engine for auto rickshaw (three wheeler) - Being a part of internal combustion engine, as held in 2009 (233) E.L.T. 218 (Tribunal), said kit is appropriately classifiable under Tariff Item 8409 99 90 of Customs Tariff Act, 1975 instead of Heading 8708 ibid - These are c....
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....duct RAIL Frame Left Hand " RAIL FR LH " is classifiable under CTI 8479 90 90 of First Schedule of Customs Tariff Act, 1975 as MACHINES AND MECHANICAL APPLIANCES HAVING INDIVIDUAL FUNCTIONS, NOT SPECIFIED OR INCLUDED ELSEWHERE IN THE CHAPTER 84 or otherwise. 8.4 At the outset, I find that the issue raised in the question in the Form CAAR-1 is squarely covered under Section 28H(2) of the Customs Act, 1962 being a matter related to classification of goods under the provisions of this Act. 9. Description of the Product As submitted by the Applicant, the subject goods i.e., RAIL Frame Left Hand: * Are used in the manufacture of car window regulator assemblies. * Provide a guided path for the window glass. * Support the regulator mechanism. * Ensure smooth, stable and quiet operation of the window system on the front-left side of the vehicle. * Act as small rollers or sliders reducing friction in guide rails. * Are integral components enabling controlled and low-friction movement of the window glass. From the technical submissions and product literature, it is evident that the goods are specifically designed and engineere....
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....hicles of headings 8701 to 8705." The subject goods: * Are identifiable as parts of motor vehicle door/window systems. * Are solely and principally used in passenger motor vehicles. * Form part of the vehicle body assembly. Sub-heading 8708 29 00 covers: Customs Authority For Advance Rulings, Mumba "Other Parts and accessories of the motor vehicles of headings 8701 to 8705." Thus, a window regulator guide rail forming part of the door/window assembly can appropriately be classifiable as a part of motor vehicle body under CTI 8708 29 00. 15. I find that Chapter 87 of the First Schedule to the Customs Tariff Act, 1975 covers goods described as "Vehicles other than railway or tramway rolling-stock, and parts accessories thereof. Chapter Heading 8708 covers "Parts and accessories of the motor vehicles of headings 8701 to 8705". Relevant portion of CTH 8708 is also reproduced below for ease of reference: 8708 Parts and Accessories of the Motor vehicles of Heading 8701 to 8705 8708 10 - Bumpers and parts thereof: 8708 10 10 --- For tractors 8708 10 90 --- Other - Other parts and accessories of bodies ....
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....8481 or 8482 or, provided they constitute integral parts of engines and motors, articles of heading 8483; (f) electrical machinery or equipment (Chapter 85); (g) articles of Chapter 90; (h) articles of Chapter 91; (ij) arms (Chapter 93); (k) luminaries and lighting fittings and parts thereof heading 9405; or (l) brushes of a kind used as parts of vehicles (heading 9603). 18. 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 part or accessory which answers to a description in two or more of the headings of those Chapters is to be classified under that heading which corresponds to the principal use of that part of accessory. 19. Thus, Section Note 2 of Section XVII restricts the application of the expression "parts" and "parts and accessories" by excluding certain articles from being classified under the chapter 87 of this Section. Clause (b) of Note 2 excludes the following: - "(b) parts of general use, as defined in Note 2 to Section XV, of base metal (Section - XV), or similar....
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....rms that this part is specifically designed to perform a function within that subsystem of the car's body. Motor vehicles are covered under headings 87.01 to 87.05 of Chapter 87 of the First Schedule to the Customs Tariff Act, 1975. Thus, the second condition is satisfied. Further, the product is not specified particularly anywhere else in the Tariff, therefore, the third condition, i.e., they must not he specifically included elsewhere in the Nomenclature is also satisfied. Since all the three conditions have been satisfied, it can be concluded that the 'RAIL FR LH' is covered under the heading 8708 only and is in accordance with classification in terms of Rule 1 of G1R, Section XVII and Chapter Notes of Customs Tariff Act, 1975. 23. Explanatory notes to the heading 8708 which contains only an illustrative list of the parts and accessories covered under that heading and not an exhaustive list. Further, just because this illustrative list may or may not contain any entry relating to any specific item (in the instant case 'RAIL FR LH') or its parts or accessories, it does not necessarily mean that the parts or accessories; which are not simply mentioned in the....
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....tirely correct to say that the end use or function of the goods is irrelevant to decide the question of classification". A three Judge Bench of the Hon'ble Supreme Court had also relied upon the function and end use in determining the classification in the case of Indian Tool Manufactures' Vs. Asst. Collector of Central Excise, Nasik & Others reported in 1994 (74) ELT 12 (SC). 25. In a recent ruling issued by this authority in the case of M/S Inalfa Gabriel Sunroof Systems Pvt. Ltd. (CMA no. 2553 of 2025) Hon'ble Madras High Court vide its order dated 10.09.2025 has upheld the classification of 'Assy Guide Rail' to be used in the manufacture of Sunroof assembly of an automobile under CTH 87082900. The Applicant in this case contended its classification under CTI 87089900 (other) and alternatively pleaded the classification under CTI 76109020 as part of structure not specified elsewhere. It is observed that in the referred case the subject goods were Assy Guide Rail' i.e. a sunroof assembly - a long, narrow track that provides support and guidance for the sunroof panel as it slides open and closed. Guide rail ensures safe, controlled movement, prevent damage a....