TaxTMI 
TaxTMI 
2024 (3) TMI 1531
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....nt is a leading automobile manufacturer and inter-alia engaged in manufacturing of a wide range of Commercial Vehicles and parts thereof for sale within India and abroad. 2.2 For manufacturing of Commercial Vehicles, Applicant is importing Urea Injectors. These Urea Injectors are part of Urea Dosing and Injection System. 2.3 The increasing individual mobility of on-road and off-road transportation in today's world has led to excessive use of human-made vehicles, such as cars, trucks, buses, etc. which produce significant emissions that can damage the human body from the inside. Currently the automotive industry is controlling auto engine emissions by three-way catalytic converters, but that solution cannot solve the diesel engine problem. The Government regulation limits are strict to reduce Nitrogen Oxide ('NOx') emissions from transportation engines considering the more and more emission every year due to increase in number of vehicle users. The diesel engine is in great demand, being used in public transportation and freight carriers, but these engines produce more NOx emissions than other types of engines. Therefore, the automotive industry is trying to improv....
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....s, mixers, and urea tanks. 2.8 Function of Urea Injector: In Urea Dosing and Injection System, the urea is pumped into the pressure line from the urea tank and the line pressure increases. The pressure sensor in the pressure line is used for feedback control and the controller generates the PWM (Pulse-Width Modulation) signal to control the speed of the Motor. The motor connects to the pump and determine the pump frequency. After the pressure is in steady state, the pumped urea mass equates to the return flow through the throttle based on the mass balance. Urea is injected into the exhaust pipe when the injection command is sent to the injector by the urea Dosing Control Unit ('DCU'). Urea Injector is a part of Urea Dosing and Injection System. The main function of Urea Injector is dosing/spraying of the precise amount of urea necessary for the SCR reactions with NOx, and mixing urea and ammonia thoroughly with the exhaust gas. Too much urea injection may cause ammonia slip and too little urea injection may result in low NOx reduction efficiency. Therefore, the injection is very critical for SCR control. 2.9 Applicant's Interpretation of Law: i. Applic....
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....g in terms of General Rules of Interpretation. Hence the urea injector cannot be classified under CTH 8708. vi. Based on the above factual and legal position, it is Applicant's interpretation that such Urea Injector would fall under HSN 84249000 of the First Schedule to the Customs Tariff Act, 1975. 2.10 In view of the above, the Applicant seeks an Advance Ruling on the classification of 'Urea Injector'. 3. Port of Import and reply from jurisdictional Commissionerate: 3.1 The applicant in their CAAR-1 indicated that they intend to import the subject goods from Commissioner of Customs (Import), Air Cargo Complex, Sahar Andheri (E), Mumbai- 400099. The application was forwarded to the jurisdictional Commissioner of Customs (Import), Air Cargo Complex, Sahar Andheri (E), Mumbai for their comments on 07.08.2023 & 18.09.2023 3.2 The jurisdictional Commissioner of Customs (Import), Air Cargo Complex, Sahar Andheri (E), Mumbai-400099 sent the comments vide their letter dated 04.10.2023 (received on 30.10.2023) however, inter-alia no comments have been made with regard to the classification of 'Urea Injector' for use in manufacturing of Commercial V....
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....nd pumps, other than those of sub-heading 8413 11 or 8413 19 u 10% - 8413 30 - Fuel, lubricating or cooling medium pumps for internal combustion piston engines: 8413 30 10 --- Injection pumps for diesel engines u 7.5% - 8413 30 20 --- Oil pump u 7.5% - 8413 30 30 --- Water pump u 7.5% - 8413 30 90 --- Other u 7.5% - 8413 40 00 - Concrete pumps u 7.5% - 8413 50 - Other reciprocating positive displacement pumps : 8413 50 10 --- Metering and dosing pumps u 7.5% - --- Primarily designed for handling water : 8413 50 21 ---- Deep tube well turbine pump u 7.5% - 8413 50 29 ---- Other u 7.5% - 8413 50 90 --- Other u 7.5% - 8413 60 - Other rotary positive displacement pumps: 8413 60 10 --- Gear type pumps u 7.5% - 8413 60 20 --- Screw type pumps u 7.5% - 8413 60 90 --- Other u 7.5% - ....
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....team, water, etc., under pressure ejected from a tube, induces a suction and entrainment effect on the liquid handled. These pumps comprise a complex system of divergent and convergent pipes in a closed chamber from which the system of pipes emerges. Injectors of the Giffard type for supplying water to boilers, and injection pumps for internal combustion piston engines, working on the same principle, are also classified here. (3) Emulsion pumps (gas lift pumps). In these, the liquid is mixed with compressed gas in the outlet pipe, the decrease in density of the emulsified liquid thus providing the lift. When compressed air is used, the pump is referred to as an air lift pump. 6.1.1 From the point D(2) above it is evident that in this type of pump the kinetic energy of a jet of air steam water etc under pressure ejected from a tube induces a suction and entrainment effect on the liquid handled. These pumps comprise a complex system of divergent and convergent pipes in a closed chamber from which the system of pipes emerges. The Injectors of the Giffard type for supplying water to boilers, and injection pumps for internal combustion piston engines working on the ....
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....SPRAY GUNS AND SIMILAR APPLIANCES Spray guns and similar hand-controlled appliances are usually designed for attaching to compressed air or steam lines, and are also connected, either directly or through a conduit, with a reservoir of the material to be projected. They are fitted with triggers or other valves for controlling the flow through the nozzle, which is usually adjustable to give a jet or more or less divergent spray. They are used for spraying paint or distemper, varnishes, oils, plastics, cement, metallic powders, textile dust, etc .. They may also be used for projecting a powerful jet of compressed air or steam for cleaning stonework in buildings, statuary, etc. The group also includes separately presented hand controlled "anti-smudge" spraying devices for fitting to printing machines, and hand controlled metal spraying pistols operating either on the principle of a blow pipe, or by the combined effect of an electric heating device and a jet of compressed air. Hand controlled spray guns with self-contained electric motor, incorporating a pump and a container for the material to be sprayed (paint, varnish, etc.), are also covered by the heading....
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....I find that the spray nozzles are specifically covered as 'Parts' under the Explanatory Notes to CH 8424. I find that such parts are classified under tariff entry 84249000. 6.3 CTH 8708: 8708 PARTS AND ACCESSORIES OF THE MOTOR VEHICLES OF HEADINGS 8701 TO 8705 8708 10 - Bumpers and parts thereof : 8708 10 10 --- For tractors kg. 15% - 8708 10 90 --- Other kg. 15% - - Other parts and accessories of bodies (including cabs) : 8708 21 00 -- Safety seat belts u 15% - *8708 22 00 -- Front windscreens (windshields), rear windows and other windows specified in Sub-heading Note 1 to this Chapter kg. 15% - 8708 29 00 -- Other kg. 15% - 8708 30 00 - Brakes and servo-brakes; parts thereof kg. 15% - 8708 40 00 - Gear boxes and parts thereof kg. 15% - 8708 50 00 - Drive-axles with differential, whether or not provided with other transmission components, Non-driving axles; parts thereof kg. 15% ....