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2026 (3) TMI 598

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....Kong (hereinafter referred to as "Logitech"), via cargo shipments at Air Cargo Complex, Hyderabad. 2. The Applicant seeks an advance ruling on the classification of "video conferencing solutions" and "webcams" (hereinafter referred to as "the subject goods"). The Applicant is of the understanding that the subject goods are classifiable under Customs Tariff Heading (CTH) 8473, being more specific to their nature and function. 2.1 The subject goods are finished webcam devices designed to operate in conjunction with video conferencing software installed on a processing unit such as a desktop, laptop, or Next Unit of Computing (NUC) for live video and audio conferencing. None of these products function independently; they require a host device to run the software, perform computing and data transmission tasks i.e. processing and generating an output in the form of a live feed. The subject goods are not capable of storing data and only work in real time. 2.2 For the sake of convenience, the subject goods are described here in three categories based on the commonality among them in terms of their functioning: a. The first category contains simple webcam models like BRIO....

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....r such usage, the user is required to purchase a cloud application license where the video application is hosted and processed. It is essential to note that even in this mode a display device still needs to be connected for viewing. These models are designed for mid-size to large meeting rooms and are fully integrated with partner platforms such as Microsoft Teams, Zoom, Google Meet, and other popular video conferencing solutions, providing a simplified device management experience. In addition to the built-in high-performance audio, be connected audio coverage. they can also to extend 2.3 Therefore, despite differences in their features and functionality, all three categories of the subject goods become operational when they are connected to any Automatic Data Processing (ADP) machines-such as a PC, laptop, or NUC - which are connected to internet, process information, and run the compatible video conferencing applications. The said goods cannot transmit or process data over the internet on their own and require connection to a host machine to function. 3 Applicant's interpretation of Law/Facts 3.1 It is submitted that the subject goods are capable of facilitating vid....

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....nbsp;     8473 21 00 -- Of the electronic calculating machines of sub-heading 8470 10,8470 21 or 8471 29 kg. Free - 8473 29 00 -- Other kg. Free - 8473 30 - Parts and accessories of the machines of heading 8471       8473 30 10 --- Microprocessors u Free - 8473 30 20 --- Motherboards u Free - 8473 30 30 --- Other mounted printed circuit boards u Free - 8473 30 40 --- Head stack u Free -   --- Other :       8473 30 91 ---- Network access controllers u Free - 8473 30 92 ---- Graphic and intelligence-based script technology (GIST) cards for multilingual computers u Free - 8473 30 99 ---- Other u Free - 3.2 Reference is invited to Chapter note 6(C) of Chapter 84, as it provides the criteria for a unit to be regarded as "part" of an ADP system; "6 (C) Subject to paragraphs (D) and (E), a unit is to be regarded as being part of an automatic data processing system if it meets all of the following conditions: (i) it is of a ....

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....DP systems by transmitting data through signals/code to the ADP machines for processing and display of the captured video and audio input, thereby meeting the third condition. 3.5 The Chapter Note 6(D) excludes certain devices from classification under heading 8471, even if they meet the conditions of Chapter Note 6(C). These exclusions include: "6(D) Heading 8471 does not cover the following when presented separately, even if they meet all of the conditions set forth in paragraph (C): (i) printers, copying machines, facsimile machines, whether or not combined; (ii) apparatus for the transmission or reception of voice, 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. " It is submitted that the subject goods do not fall under these exclusions. In particular, web cameras are distinct from television cameras, digital cameras, and video camera recorders. This distin....

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.... that the web camera imported by the appellant is not an ordinary camera and does not function independently. The image can be captured only when it is connected with the computer. Thus from the above, it can be seen that the product imported by the appellants is not an ordinary camera and therefore will not fall under chapter 90 as held by the lower authority. The proper classification will be under chapter 84.73 or 84.71. Besides, a perusal of the aforesaid judgment of the Hon'ble Tribunal also clearly indicates that all those items which come along with the computer are to be treated as spares and accessories. " 3.7 It is also helpful to note the definition of accessory. a. In Black's Law Dictionary (Fifth Edition) accessory is defined as, "anything which is joined to another thing as an ornament or to render it more perfect, or which accompanies it, or is connected with it as an incident, or as subordinate to it, or which belongs to or with it, adjunct or accompaniment. A thing to subordinate importance. Aiding or contributing in secondary way of assisting in or contributing to as a subordinate." b. Similarly, Oxford Dictionary defines "accessory" a....

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.... The application was forwarded to the Office of the Commissioner of Customs, ACC, Chennai-VII for their comments vide letter dated 05.09.2025 and 01.10.2025. Comments were received from the jurisdictional authorities vide letter dated 01.10.2025 wherein it was submitted that - Classification: i. The application for Advance Ruling is filed for classification of the following items imported by the applicant: a. WEBCAM-BRI04K. b. WEBCAM, Logitech C505e. c. WEBCAM, Logitech B525 HD d. WEBCAM, Logitech C925e. e. WEBCAM, LogitechC920e HD 1080p. f. WEBCAM, Logitech Brio. g. Rally Camera. h. PTZ PRO 2. i. WEBCAM, Logitech Sight. j. WEBCAM, Logitech C930. k. Logitech BCC950. l. Logitech MEETUP. m. Logitech RALLY PLUS. n. Logitech Group. o. Logitech Rally System p. WEBCAM - Rally Bar Huddle - Graphite. q. WEBCAM - Rally Bar Mini - Off White. r. WEBCAM - Rally Bar Mini - Graphite. s. WEBCAM - Rally Bar - Graphite. t. WEBCAM - Rally Bar -- Off White. ii. The applicant submitted that they in....

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....cation and quoted case- laws in favour of the same which does not appear to suit their case given the nature of the cargo intended to be imported & cleared by them. vii. The items intended to be imported by the applicant i.e., Video Conferencing Equipment/Web cameras are designed to facilitate video and audio communication and are apparatus for the transmission or reception of voice, images, or other data for communication in a wired or wireless network and therefore appears to be more appropriately covered under CTH 8517 and not under CTH 8473. viii. To press their case, the applicant impressed on the Chapter Note 6(c) of Chapter 84 and stated that the items qualify the definition of the part as prescribed. However, the said consideration is subject to subsequent paras of said Chapter Note i.e. 6 (D) and (E), ix. The applicant in their application stated that the they intend to import above said 20 items. Chapter Note 6 (d) of Chapter 84 states; "Heading 8471 does not cover the following when presented separately, even if they meet all of the conditions set forth in paragraph (C): i. printers, copying machines, facsimile machines, whether or not....

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.... enclosed herewith. xv. Further, a similar investigation is pending with the DRI, Mumbai into the import of subject items from the same supplier, by the importer M/s. Select Technologies Private Limited, through the formations under O/o the Principal Commissioner of Customs, Hyderabad. xvi. Thus, the items appear to be more appropriately covered under CTH 8517.62.90 and not under CTH 8473. 30.99. 4.2 The applicant has submitted their rebuttal vide letter dated 06.10.2025 wherein they have submitted that the department in para-B (vi) has argued that the applicant is "conveniently swaying between parts and accessories" and the case laws relied upon by the applicant do not pertain to the subject goods and their application is misconceived It is unequivocally denied, as there is no inconsistency in the applicant's submissions. Heading 8473 itself covers "parts and accessories", the applicant has made out a case for both parts and accessories in the application. 4.3 The descriptions of the impugned products in the both the judgements, in Hi-Tech Computers v. CC (2004 (9) TMI 262 - CESTAT Bangalore), in Xiaomi Technology (2023 (12) TMI 447 - CCESTAT Bangalore)....

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....sion and reception. Therefore, under CTH 8517 Modems, Routers, Network interrace cards etc are covered and a peripheral input device like a web-camera is not. The same is incapable of transmission or reception of any data from one end to another, whatsoever and is thus not classifiable under Heading 8517. 4.7 The only ostensible inference that can be drawn from putting together the assertions in paras B(vii to x) is that it is department's case that the subject goods fall under the exception Chapter Note 6(D) (ii) and therefore the more appropriate description is CTH 8517 as both cover, "apparatus for the transmission or reception of voice. images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network);". But as stated above, the web-cameras at hand are not transmission or reception devices. 4.8 Furthermore, Note 6(d) to Chapter 84 does not preclude classifying the subject goods as a "part" under CTH 8473, since it is designed to exclude parts specifically from CTH 8471 rather than CTH 8473. Additionally, the advance ruling application presents an alternative argument for classifying them under CTH 8473 as....

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....ier, the subject devices cannot transmit images or data independently. They merely capture input, which is processed and transmitted by the host computer. They are therefore input devices, not transmission devices. The foreign judgment fails to recognize this distinction. 4.11 Notwithstanding the above, with regard to para B(xiv) & (xv), it is submitted that all products submitted by the applicant are more appropriately classifiable under. Heading 8473, even going as per the reasons mentioned in the SCN issued to M/s. Shree Info Systems Solutions Private Limited in the following manner: Findings of the SCN issued to M/s. Shree Info Systems Solutions Private Limited Remarks "7.1. From the technical literature/ datasheets it was apparent that the above products being imported by the Importer were Video Conferencing solutions, plug-and-play compatible with applications such as BlueJeans, Broadsoft, LifeSize(r) Cloud, Zoom, Vidyo and certified for Skype(r) for Business, Microsoft Teams, Cisco JabberTM, etc. Further, the built-in computing has enabled video conferencing applications to run directly on the device without a computer and standards such as H.264, Scalable Video ....

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....ng compatible with VoIP software does not equate to embedding VoIP protocols in the hardware. 7.3 As regards video codecs, the same are based on algorithms for encoding and decoding video data that allow for high quality and high- resolution video streaming. The H.264 specification describes the Advanced video coding (AVC) for generic audiovisual services. The H.264/ AVC standard is by far the most commonly used format for the recording, compression, and distribution of video content. The intent of the H.264/ Advanced video coding (AVC) project mas to create a standard capable of providing good video quality at substantially lower bit rates than previous standards. The Scalable Video Coding (SVC) feature, specified in Annex G of. H.264, allows the construction of bitstreams that contain layers of sub-bitstreams that also conform to the standard. Further, the USB Video Class (UVC) is a specification that standardizes video streaming functionality on the Universal Serial Bus (USB). This specification includes support for compressed video streams, including the H.264 codec and governs devices capable of streaming audio and video. UVC cameras, which are USB. powered devices, seamles....

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....ed that the subject goods they intend to import pertains to video conferencing equipment/web camera which designed to facilitate video and audio communication when connected to and ADP machine like PC, laptop etc. She contended that the said product i.e. web cameras are of three categories and merit classification under CTH 8473 more particularly under 84733099 as part and accessories of the machines under CTH 8471. She relied upon chapter note 6 (c) of chapter 84. In support of her claim, she also relied upon reference in the matter of Hi-Tech Computers v. CC (2004 (9) TMI 262 - CESTAT Bangalore), Xiaomi Technology (2023 (12) TMI 447 - CCESTAT Bangalore) and others. 5.1 Nobody appeared on behalf of the Department for hearing. 5.2 The applicant vide letter dated 19.11.2025 has made additional submission wherein they reiterated the contention made in the application. Discussion and findings 6.1 I have considered all the materials placed before me in respect of the subject goods. I have gone through the submissions made by the applicant during the personal hearing and comments received from the concerned Commissionerate. I proceed to pronounce a ruling o....

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....import of Video Conferencing equipment by M/s. Ingram Micro India Pvt. Ltd., the Deputy Commissioner of Customs, ACC, Mumbai, vide Order-in-Original dated 28.02.2017 had held that the Cisco Video Conferencing System was classifiable under CTI 8517 6290 and the same was denied concessional duty benefit as provided under Sr. No. 13 of Notification No. 24/2005-Cus. dated 01.03.2005 as the impugned goods were held to be VoIP equipment which were excluded from the aforesaid duty benefit under Notification No. 11/2014-Cus. dated 11.07.2014. Against the said Order-in-Original, M/s. Ingram Micro India Pvt. Ltd, filed appeal before Commissioner (Appeals), wherein vide Order-in-Appeal No.896/2017-18 dated 26.12.2017 it was held that both VoIP and Video Conferencing Equipment were based on H.323 and SIP protocols which allowed a device such as desk phone, soft phone or video conferencing system to place a video call (including audio call) to another person over IP. The VolP phone and video conferencing system were held to be one and same with respect to their functioning as both transmit data from one end to another over IP using same protocols; having only one difference that VoIP phone was ....

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.... the comments of the TEC further opined that the video conferencing equipment/Telepresence (Model No. CTS-SX20-PHD12XX-K9) is VOIP equipment used for point to point and/or Point to Multipoint video conferencing using H.323/SIP/VOIP in the same conference. Based on the aforesaid opinion, Hon'ble CESTAT upheld the aforesaid Order-in- Appeal and dismissed the appeal filed by M/s. Ingram Micro India Pvt. Ltd vide Order No. A/85145/2019 dated 22.01.2019. Aggrieved by the CESTAT order, M/s. Ingram Micro India Pvt. Ltd. filed an appeal before the Hon'ble Supreme Court. However, the Apex Court vide Order dated 19.08.2019 have dismissed the appeal citing no ground to interfere with the impugned order passed by the Tribunal. Thus, the matter stood finally settled up to the Hon'ble Supreme Court that video conferencing system, based on H.323/SIP protocol, is a VoIP equipment. 6.7 Analysis of the Technical Datasheets: The datasheets/ technical literature pertaining to the impugned goods are perused and are summarised below: . Sr. No. Product Description Functions/Features as per catalogue submitted by the applicant 1 BRIO 4K (P/N- 960-001755) Brio is designe....

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....tm) and compatible with other popular applications include Blue Jeans, Cisco Webex(r), Fuze, Google Meet(tm). Go To Meeting(tm)^ and Microsoft DirectShow. Dual omni- directional mics provided. 7 Rally Camera (P/N- 960- 001226) Rally Camera tops the lineup of standalone video camera's from Logitech(r). USB plug-and-play ensures compatibility with every leading video conferencing software platform with no additional software required. The Rally Camera is UVC/plug-and-play compatible with virtually any cloud based video conference application. Certified for Skype(r) for Business and ready for Teams. Compatible with Google(tm) Hangouts Meet, Zoom, Blue Jeans, Broadsoft, GoToMeeting(tm), Vidyo and other video conferencing, recording and broadcasting application. 8 PTZ Pro 2 (P/N- 960- 001184) Logitech(r) PTZ Pro 2 camera delivers premium optics and life-like video calls. H.264 UVC 1.5 with Scalable Video Coding (SVC) - Advanced camera technology frees up bandwidth by processing video within the PTZ camera, resulting in a smoother video stream in applications like Microsoft(r)Skype(r) for Business. UVC/plug-and-play compatible with no additional software required. ....

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....gineered lens, Ultra HD 4K optics, and three camera presets deliver remarkable video quality. With an ultra-wide motorized lens, integrated audio, and a two-way table stand / wall mount, MeetUp reduces cross room cabling. Built-in Components include Ultra HD camera with motorized pan/tilt, integrated microphone with 3 beamforming elements, full range speaker, integrated table stand/wall mount. Compatible with virtually any video conferencing software app. UVC/plug-and-play compatible with no additional software required and certified for Skype(r) for Business, Cisco Jabber compatible. Enhanced integration with BlueJeans, Broadsoft, LifeSize(r) Cloud, Vidyo and Zoom. 13 Rally Plus (P/N- 960- 001275) Logitech(r) Rally Plus offers an Ultra-HD imaging system, delivering brilliantly sharp video, outstanding color, and exceptional optical accuracy at resolutions up to 4K. The modular audio system brings crisp, clear audio and unmatched voice clarity to the table. Right Sense is compatible with most any video conferencing application that works with USB devices, including Google(r) Hangouts(tm) Meet, Microsoft(r) Skype(r) for Business and Teams, and Zoom. The Logitech(r) Rally Pl....

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.... Central Rooms, and Tencent Meeting Rooms. Plug and play with virtually any PC or Mac, or run supported video conferencing applications on the device without a computer. Built-in compute supported video conferencing applications such as Zoom directly on the device. 18 RALLY BAR (P/N- 960- 001329 & 960-001317 and 960-001745) Rally Bar features a multi-element lens assembly, powerful low distortion speakers, and an advanced mic system. Built- in Components include, 6 beamforming microphones, PTZ (Pan-Tilt-Zoom) camera, 2 speakers, AI Viewfinder, cable management & retention system, table stand, Logitech Collab OS platform. Built-in compute supports video conferencing applications such as Zoom directly on the device. Certified for Skype(r) for Business and ready for Teams. Fully integrated with partner solutions like Microsoft Teams, Zoom, and others for a simplified device management experience. From the facts, catalogue and specifications submitted by the applicant, it is clear that the subject goods cannot be regarded as "part" of an ADP system; as the goods are not of a kind solely or principally used in an automatic data processing system. They can be used independent....

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....ming audio and video. UVC cameras, which are USB-powered devices, seamlessly connect with host machines to provide video streaming capabilities. The latest version of the USB video class specification is UVC 1.5. Almost all video conferencing and web conferencing applications are UVC compatible, that is why Logitech video and audio products work across all applications without needing additional software drivers. Further, in the case of Shree Info System Solutions Private Limited, the Director (WR), Regional Telecom Engineering Centre, Mumbai vide letter dated 27.02.2024 have confirmed that subject goods have the capabilities to be used as part of the VoIP System. The contents of the said letter are reproduced below: "The undersigned is directed to refer to your office letter under reference vide which technical opinion/comments were sought on the issue whether the given set of goods fall under the category of VolP equipment or otherwise. In this regard, it may be noted that the technical details of the goods made available have been examined in this office and it is opined that the given set of goods have the capabilities to be used as part of the VOIP System". F....

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....audio communication and are apparatus for the transmission or reception of voice, images, or other data for communication in a wired or wireless network. As the subject goods are not of a kind solely or principally used in an automatic data processing system and can perform independently. Notes 6(C) is subject to Note 6(D) that clearly excludes the apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network). In terms of General Rules of Interpretation (GIR) 1 of the Tariff, the classification of imported goods is required to be determined according to the terms of heading and any relative Section or chapter note. VolP equipment supports transmission of voice, video, and data over IP networks. From the description and the functionality of the said goods imported by the applicant it is apparent that the same are classifiable under heading 8517 and the single dash sub-heading thereunder pertaining to 'other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a....