TaxTMI 
TaxTMI 
2024 (6) TMI 1564
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....8H (1) of the Customs Act, 1962 (hereinafter referred to as the 'Act'). The enclosed application is submitted to seek confirmation whether the classification adopted by the Applicant under the Customs Tariff Heading 8504 40 10 of the First Schedule of the Customs Tariff Act, 1975 in relation to import of the product "Inverter Assembly" is correct, and the Applicant is eligible to avail concessional rate of Basic Customs Duty under SI. No. 13 of the Notification No. 57/2017-Customs dated 30.06.2017 (as amended). Further, whether the applicant is eligible to avail concessional rate of Basic Customs Duty on import of the subject goods as per SI. No. 646 of the Notification No. 69/2011-Customs dated 29.07.2011. STATMENT OF FACTS AND QUESTION LAW 1.1 The application is being preferred by M/s. Denso Haryana Private Limited ('Applicant') a company incorporated in India under the provisions of the Companies Act, 1956 and having its registered head office located at New Delhi. Copy of Certificate of Incorporation, Articles of Association and Memorandum of Association (as submitted with the Registrar of Companies in India) is enclosed herewith as Appendix 1 (Colly). ....
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....m, only one quantity of the subject good will be installed in the front portion of the EV. If the EV uses 4WD driving system, two quantities of the subject good will be used - one in the front (to power the front motor for front wheels rotation) and another at the rear section of the EV (to power the rear motor for rear wheels rotation). Diagrammatic representation of the two driving systems with subject good (depicted as 'FrInv' and 'RrInv') installed is captured below - 1.6 To understand how the subject good performs its principal function of conversion of current from DC to AC and vice versa, it is crucial to understand the technical features and key components of the subject good. Before proceeding further with the key components, the exploded view of the inverter diagram is captured below. 1.7 As evident from the picture above, the Inverter is comprised of key components such as case, printed circuit board ('PCB'), cooler, power card, thermistor: a) The PCB is housed in the metal case which is the broad skeleton of the subject good. PCB has resister, capacitor, and other Integrated Circuit ('IC') parts populated on the PCB. PCB contro....
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....Question raised in the application for advance ruling by the Applicant squarely falls within the ambit of Section 28H(2)(a) of the Customs Act-Section 28H of the Customs Act provides for the questions in respect of which an advance ruling may be sought by an applicant. Section 28H of the Customs Act reads as under - "28H. Application for advance ruling - (1) An applicant desirous of obtaining an advance ruling under this Chapter may make an application in such form and in such manner and accompanied by such fee as may be prescribed, stating the question on which the advance ruling is sought. (2) The question on which the advance ruling is sought shall be in respect of, - (a) classification of goods under the Customs Tariff Act, 1975 (51 of 1975); (b) applicability of a notification issued under sub-section (1) of section 25, having a bearing on the rate of duty; (c) the principles to be adopted for the purposes of determination of value of the goods under the provisions of this Act. (d) applicability of notifications issued in respect of tax or duties under this Act or the Customs Tariff Act, 1975 (51 of 1975) or any ta....
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....has been issued nor the bill of entries has been provisionally assessed. Thus, relying on the above the facts of the current case, Applicant submits that in its case, the application shall be accepted for hearing on merits by the Hon'ble CAAR. The Applicant wishes to obtain the advance ruling on the questions listed down in form CAAR -1 (as also appearing in Annexure II). Hence, the Applicant has proceeded to file this application before the Hon'ble CAAR, New Delhi for kind consideration. The Applicant humbly submits that the Hon'ble CAAR may kindly issue the advance ruling addressing the questions of law raised in the present application at an early date. 1.15 The Applicant is presently engaged in the business of manufacturing and trading of parts of automobiles. For its trading business, the Applicant inter alia imports automotive parts in finished form for further supply of these automotive parts to the manufacturers of motor vehicles in India. For the present application, the proposed activity pertains to the import of subject good from Denso Japan. 1.16 The questions in respect of which an advance ruling has been sought by the Applicant are: ....
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....n given statutory backing and have been incorporated at the beginning of each Section / Chapter. For ready reference, Rule 1 is extracted herein below: "Classification of goods in this Schedule shall be governed by the following principles": The titles of Sections, Chapters and Sub-Chapters are provided for ease of reference only; for legal purposes, classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes and, provided such headings or Notes do not otherwise require, according to the following provisions 1.19 The Larger Bench of the Hon'ble Tribunal in the matter of Saurashtra Chemical, Porbandar vs. Collector of Customs, 1986 (23) E.L.T. 283 (Tri. - LB) had held that the tariffs must be interpreted in the light of relevant Section and Chapter Notes which are statutorily binding like the Headings themselves. Thus, the Section and Chapter Notes have an overriding force on the respective Headings. This judgment was approved by the Hon'ble Supreme Court of India in the case of Saurashtra Chemicals vs. Collector of Customs, 1997 (95) E.L.T. 455 (S.C.). Harmonized System of Nomenclature (HSN) ....
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....al function of the subject good. To ascertain the classification and by application of GRI 1, the following Customs Tariff Heading ('CTH') require attention i.e., CTH 8504 and CTH 8708. CTH Description of Goods 8504 Electrical transformers, static converters (for example, rectifiers) and inductors. 8708 Parts and accessories of the Motor Vehicles of Heading 8701 to 8705 Analysis of Chapter 85 1.24 Given the above, CTH 8504 merits consideration, which provides for "electrical transformers, static converters (for example, rectifiers) and inductors". As stated in Annexure 1 above, the subject good imported by the Applicant is an inverter which is going to be used in the electric vehicles. CTH Description of Goods 8504 Electrical transformers, static converters (for example, rectifiers) and inductors. 8504 40 - Static Converters 8504 40 10 -- Electric Inverter As per Rule 1 of the GRI, subject good should be classified in accordance with the terms of the headings and any relevant and Section or Chapter Notes. 1.25 CTH 8504 covers electrical transformers, static converters (for example, rect....
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....a whole and is going to be used in the electric vehicle merits classification under the Chapter 85 only. 1.29 To substantiate the above, reliance can be placed on the US Cross Ruling numbered NY N306512 dated 25.10.2019 wherein the applicant was importing power inverters and electrical chargers. In the said case, it was held that "The applicable subheading for the DC/AC, AC/DC Inverter/Charger will be 8504.40.9570, HTSUS, which provides for "Electric transformers, static converters and inductors ...: Static converters: Other: Inverters." Copy of the same is annexed as Appendix 3. 1.30 Also, reliance can also be placed on the US Cross Ruling numbered NY G86580 dated 06.02.2001 wherein power inverters were being imported by the applicant to be used on the roofs of US streetcars. In the said case it was held that "the applicable subheading for this power inverter is 8504.40.9570, Harmonized Tariff Schedule of the United States (HTS), which provides for "Electrical transformers, static converters and inductors; Static converters: Other; Inverters". Copy of the same is annexed as Appendix 4. 1.31 Since the HSN is aligned, these rulings have persuasive value for determining the ....
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.... an electrical machinery or equipment of Chapter 85. Further, the HSN explanatory notes under Section XVII explain the scope of the terms "parts and accessories" for the purpose of Section XVII. Relevant portion is extracted hereunder - III) PARTS AND ACCESSORIES It should be noted that Chapter 89 makes no provision for parts (other than hulls) or accessories of ships, boats or floating structures. Such parts and accessories, even if identifiable as being for ships etc., are therefore classified in other Chapters in their respective headings. The other Chapters of this Section each provide for the classification of parts and accessories of vehicles, aircraft or equipment concerned. It should, however be noted that these headings apply only to those parts or accessories which comply with all three of the following conditions: They must not be excluded by the terms of Note 2 to this Section (see Paragraph (A) below), They must be suitable for use solely or principally with the articles of Chapter 86 to 88 (see paragraph (B) below, and They must not be more specifically included elsewhere in the Nomenclature (see paragraph (C) below: ....
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.... UP, 2008 (225) E.L.T. 321 (S.C.) wherein it was held by the Hon'ble Supreme Court that if there is a conflict between two entries one leading to an opinion that it comes within purview of tariff entry and another the residuary entry, the former should be preferred. 1.37 Further, in the case of Dunlop India Ltd. & Madras Rubber Factory Ltd. vs. Union of India and Ors., 1983 (13) E.L.T. 1566 (S.C.), it was held by the Hon'ble Supreme Court that an article classifiable under specific item cannot be classified under residuary Item. 1.38 Further, reliance is placed on the decision of Hon'ble Tribunal, Mumbai bench in the case of Sirthai Superware India Ltd. v. Commr. of Customs, Nhava Sheva-III, 2020 (371) E.L.T. 324 (Tri. - Mumbai), where the Tribunal observed that it is general principle of classification that specific entry should be preferred over the general entry. 1.39 Therefore, it is submitted that where the goods satisfy the requirements of a specific entry, that entry should cover the goods rather than the residual heading. In view of GRI 3(a) and the judicial precedents cited above, where there is a specific heading for the subject good under Chapter 85 ....
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....ccessories" do not apply to the electrical machinery or equipment (Chapter 85). Furthermore, there is a more specific CTH as against general CTH under Chapter 87. Therefore, the product under consideration cannot be classified under the Chapter 87 in view of the conditions at point (a) and (c) of the aforementioned circular issued by the Commissioner's office. The principal of classification discussed in the Hon'ble Supreme Court's decisions can be summarized as under. 1.43 In the Westinghouse judgment (supra), the end use test to determine the classification has been preferred over the exclusion provided under Note 2(f) to Section XVII. The judgment of the Supreme Court in the matter of Commissioner of Central Excise, Aurangabad v. M/s. Videocon Industries Limited (2023- TIOL-25-SC-CUS) has emphasized on the exclusion note over the sole/ principal use test. 1.44 Further, post the judgement of the Hon'ble Supreme Court in the case of Westinghouse Saxby (supra), the CBIC on 5th January 2022 issued instruction No. 01/2022-Customs with subject "Implication of the judgement of the Hon'ble Supreme Court in the case of M/s Westinghouse Saxby Farmer Ltd.....
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....e of the items. It was recognized that since one of the conditions i.e. of the exclusions mentioned in Note 2 (condition (a)) was not met, the said goods could not be classified under Chapter 87." 1.46 Taking cognizance of the rationale laid down in the judgement in the matter of M/s Intel Design Systems (India) P. Ltd. Vs Commissioner of Customs & Central Excise and the instructions issued by the CBIC as discussed above, for goods to be classified under the chapters of Section XVII, fulfilment of the three-layer test postulated "Under the Sub-heading (iii) Parts and Accessories" of the explanatory notes to Section XVII as issued by the WCO is imperative. It is only when all these three conditions are met that a particular item would be classified under the Chapters of Section XVII. 1.47 In other words, the shape/ design/ specification of a product is not a determinant of principal or sole use. Further, Note 3 of Section XVII cannot be applied blanketly and needs to be construed narrowly otherwise the exclusion under Note 2 would become superfluous. To this extent, the Videocon judgment is particularly important, and it is also aligned with the WCO classification principles a....
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.... 57/2017-CUSTOMS DATED 30.06.2017. 1.51 The Central Government vide Notification No. 57/2017-Cus. dated 30.06.2017 ('NN 57/2017') intends to provide concessional exemption benefit to the import of machinery items, electrical appliances and its parts and accessories covered in the notification. In this regard, NN 57/2017 vide its S. No. 13 has provided concessional benefit to all the goods falling under CTH 8504 40 to the extent of 10% BCD under the First Schedule of Tariff Act except the charger or power adapter or solar inverters of CTH 8504 40. Copy of the NN 57/2017 is annexed with this application as Appendix 8. 1.52 It is the understanding of the Applicant that the benefit provided under the notification is unconditional as there is no condition annexed to the S. No. 13 of the NN 57/2017 for availing benefit on import of items of CTH 8504 40. So long as the imported goods are rightly classifiable under CTH 8504 40 and are not in the nature of charger/ adapter or solar inverter, the same are eligible to avail concessional duty benefit @ 10% BCD. Relevant S. No. 13 of the NN 57/2017 is extracted hereunder for ease of reference. S. No. Chapter, Heading, Sub-he....
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....the Hon'ble Authority as follows: a) The subject good is correctly classifiable under Customs Tariff Heading 8504 40 10 of the First Schedule of the Tariff Act. b) The Applicant is eligible to avail concessional rate of BCD @10% as per S. No. 13 to NN 57/2017 on import of subject good. c) The applicant is eligible to avail concessional rate of BCD @ 0% as per S. No. 646 to Notification No. 69/2011-Cus dated 29.07.2011 on import of subject goods subject to satisfaction of origin criteria that the goods are originating from Japan. 2. The Comments of the Airport & ACC (Import) Customs Commissionerate, Bengaluru with regard to points raised in the application are furnished as under: 2.1 Eligibility of the applicant, in terms of section 28-E (c) of the Customs Act, 1962 to seek such advance ruling. As per section 28-E(c): (c)"applicant" means any person- (i) holding a valid Importer-exporter Code Number granted under section 7 of the Foreign Trade (Development and Regulation) Act, 1992; or (ii) exporting any goods to India; or (iii) with a justifiable cause to the satisfaction of the Authority, who makes an appl....
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.... --- Rectifier : 8504 40 21 ---- Dip bridge rectifier 8504 40 29 ---- Other 8504 40 30 --- Battery chargers 8504 40 40 --- Voltage regulator and stabilizers (other than automatic) 8504 40 90 --- Other (ii) In terms of explanatory notes for CTH 850440 published by the WCO: "The apparatus of this group are used to convert electrical energy in order to adapt it for further use. They incorporate converting elements (e.g., valves) of different types. They may also incorporate various auxiliary devices (e.g., transformers, induction coils, resistors, command regulators, etc.). Their operation is based on the principle that the converting elements act alternately as conductors and non- conductors. The fact that these apparatuses often incorporate auxiliary circuits to regulate the voltage of the emerging current does not affect their classification in this group, nor does the fact that they are sometimes referred to as voltage or current regulators. This group includes: a) Rectifiers by which alternating current (single or polyphase) is converted to direct current, generally accompanied by a ....
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....en the Republic of India and Japan) Rules, 2011 are complied with. 3. The applicant has submitted the response to the observations of the field Commissionerate, which was received by the CAAR office, which are as follows: 3.1 This letter is furtherance to the Application dated 18.03.2024 (filed on 26.03.2024) for Customs Advance Ruling under Section 28H of the Customs Act, 1962 ('Customs Act') filed by M/s. DENSO Haryana Pvt. Ltd. ('Applicant') for seeking clarity on the issue of classification of goods namely 'Inverter Assembly' and eligibility to avail benefit of concessional rate of duty under Sr. No. 13 of Notification No. 57/2017-Cus. dated 30.06.2017 ('Notification No. 57/2017') and Sr. No. 666 of Notification No. 69/2011- Cus. dated 29.07.2011 ('Notification No. 69/2011'), upon its import into India. 3.2 In this regard, the authorized representatives of the Applicant had appeared before CAAR Delhi on 21.05.2024 and presented its detailed submissions in relation to the Customs Advance Ruling sought by the Applicant and the comments provided by the Ld. Additional Commissioner, Rajaji Salai, Chennai. Now on 28.05.2024, the Applic....
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....he 'Inverter Assembly' merits classification under CTH 8504 40 90 which is a residuary entry and cover "Other" Static Converters. That being so, the Applicant's additional arguments (in addition to the reasons submitted in the CAAR application concerned) are captured herein below: 3.6.3 Classification ought to be done on principal function of the 'Inverter Assembly' and not the nomenclature adopted by the Applicant: It is a settled principle of classification that for purposes of classification of a product, the nomenclature is not of much relevance, what is relevant is the principal function of the product. 3.6.4 As per the ACC, Bengaluru, the product imported by the Applicant is "Inverter Assembly" used in motor vehicles and hence the same is not "Electric Inverter", therefore, the same cannot be classified under CTH 8504 40 10 and the same merits classification under the residuary entry, i.e., CTH 8504 40 90. This understanding is totally erroneous as the ACC, Bengaluru Commissionerate has determined the classification of the Inverter Assembly at eight-digit level based on the nomenclature adopted by the Applicant to describe the product under considera....
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....ssification in the four-digit headings. In such a case, the terms of the subheadings or sub-heading Notes must be given precedence. Thus, the whole classification process as done for classification at four-digit or heading level has to be repeated again as a separate exercise to choose the six-digit subheading and then again for the eight-digit level. 3.8.2 Accordingly, in terms of GIR 6, the whole process of classification must be repeated to determine the classification of Inverter Assembly at eight-digit level and sequential application of GIR I to GIR 5 have to be re-applied to determine the classification at six-digit and eight-digit level. As per GIR 1, classification of a product ought to be done based on the terms of heading. Hence, upon perusal of the entries under CTSH 8504 40, we are of the opinion that based on the terms of sub-heading under CTSH 8504 40, the Inverter Assembly is classifiable under CTH 8504 40 10 which covers "Electric Inverters" as the same is capable converting AC to DC and vice versa. 3.8.3 Without prejudice, reliance may also be placed on GIR 3(a) for classification Inverter Assembly imported by the Applicant. As per GIR 3(a), when there are t....
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....f different types. They may also incorporate various auxiliary devices (e.g., transformers, induction coils, resistors, command regulators, etc.). Their operation is based on the principle that the converting elements act alternately as conductors and non- conductors. The fact that these apparatuses often incorporate auxiliary circuits to regulate the voltage of the emerging current does not affect their classification in this group, nor does the fact that they are sometimes referred to as voltage or current regulators. This group includes: a) Rectifiers by which alternating current (single or polyphase) is converted to direct current, generally accompanied by a voltage change. b) Inverters by which direct current is converted to alternating current. c) Alternating current converters and cycle converters by which alternating current (single or polyphase) is converted to a different frequency or voltage. d) Direct current converters by which direct current is converted to a different voltage." (iii) It is clear that CTH 850440 covers Static Converters i.e. which convert the direct current to alternating currents and vice versa. H....
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....ds under a specific Heading whereas GRI 6 is applicable if the objective is to determine the classification of goods in the Sub- headings of a Heading. The Larger Bench of the Hon'ble Tribunal in the matter of Saurashtra Chemical, Porbandar vs. Collector of Customs, 1986 (23) E.L.T. 283 (Tri. - LB) had held that the tariffs must be interpreted in the light of relevant Section and Chapter Notes which are statutorily binding like the Headings themselves. In the light of above facts, to analyze the classification of above product following needs to be kept in mind: i. General Rules of Interpretation (GRI); ii. Heading/sub-heading of the First Schedule in conjunction with Section/Chapter/Explanatory notes; iii. Principal function of the subject good. 6.1.1 To ascertain the classification and by application of GRI 1, the following Customs Tariff Heading ('CTH') require attention i.e., CTH 8504 and CTH 8708. CTH Description of Goods 8504 Electrical transformers, static converters (for example, rectifiers) and inductors. 8708 Parts and accessories of the Motor Vehicles of Heading 8701 to 8705 6.1.2 Analysis of Chapter 85: G....
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...., it is also imperative to refer Note 2 (a) of Section XVI which provides for classification of parts of machines. It states that parts which are goods of any heading of Chapter 84 or 85 are in all cases to be classified in the respective headings. Relevant extract of Section Note has been reproduced below for ease of reference - "(a) parts which are goods included in any of the headings of Chapter 84 or 85 (other than headings 8409, 8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 8538 and 8548) are in all cases to be classified in their respective headings;" (Emphasis supplied) Therefore, upon bare reading of the above stated Section Note, it can be construed that the inverter which is a good/product as a whole and is going to be used in the electric vehicle merits classification under the Chapter 85 only. 6.1.6 To substantiate the above, reliance can be placed on the US Cross Ruling numbered NY N306512 dated 25.10.2019 wherein the applicant was importing power inverters and electrical chargers. In the said case, it was held that "The applicable subheading for the DC/AC, AC/DC Inverter/Charger will be 8504.40.9570, HTSUS, which provides for "Electric transformers....
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....rther, apparently, the section notes have been suitably applied in relevant judgements of the Hon'ble Supreme Court on issues of classification of parts and accessories. Thus, the collective wisdom of these judgments indicates the manner in which such classification issues are to be approached. Few of such judgments are illustrated in succeeding paragraphs: 3.1 of M/s Intel Design Systems (India) P. Ltd. Vs Commissioner of Customs & C. Ex-2008 A. Apart from the reliance on the section notes and the chapter notes the court in this judgment also considered the HSN explanatory notes wherein three conditions that need to be fulfilled for goods to be classified under section XVII are mentioned namely - a. They must not be excluded by the terms of Note 2 to Section XVII and b. They must be suitable for use solely or principally with the articles of chapter 86 to 88 and c. They must not be more specifically included elsewhere in the nomenclature B. While relying on these conditions, the Hon'ble Supreme Court held - "The items, therefore, manufactured by the appellants are identifiable or are in the nature of goods fall....
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....rovided for the electric inverters i.e., CTH 8504 40 10. 6.2 APPLICABILITY OF NOTIFICATION NO 57/2017-CUSTOMS DATED 30.06.2017. i) The Central Government vide Notification No. 57/2017-Cus. dated 30.06.2017 ('NN 57/2017') intends to provide concessional exemption benefit to the import of machinery items, electrical appliances and its parts and accessories covered in the notification. In this regard, NN 57/2017 vide its S. No. 13 has provided concessional benefit to all the goods falling under CTH 8504 40 to the extent of 10% BCD under the First Schedule of Tariff Act except the charger or power adapter or solar inverters of CTH 8504 40. Copy of the NN 57/2017. ii) It is the understanding of the Applicant that the benefit provided under the notification is unconditional as there is no condition annexed to the S. No. 13 of the NN 57/2017 for availing benefit on import of items of CTH 8504 40. So long as the imported goods are rightly classifiable under CTH 8504 40 and are not in the nature of charger/ adapter or solar inverter, the same are eligible to avail concessional duty benefit @ 10% BCD. Relevant S. No. 13 of the NN 57/2017 is extracted hereunder fo....
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....2 As per the letter dated 21.05.2024, the Port Commissionerate of ICD Bangalore is in conformity with the classification of Inverter Assembly under CTH 8504 40 10, as adopted by the Applicant. Further, it has been confirmed that the Applicant to avail concessional rate of Basic Customs Duty ('BCD') under Sr. No. 13 of the Notification No. 57/2017 and Sr. No. 646 of Notification No. 69/2011, on import of Inverter Assembly. Further, as per the letter dated 24.05.2024, the Port Commissionerate of ACC Bangalore has agreed with the classification of Inverter Assembly adopted by the Applicant, up to sub-heading level or six- digit level, i.e., CTSH 8504 40. However, they have opined the classification of Inverter Assembly at eight- digit level under CTH 8504 40 90. But the Port Commissionerate of ACC Bangalore has also confirmed the eligibility of the Applicant to avail concessional rate of BCD under Sr. No. 13 of the Notification No. 57/2017 and Sr. No. 646 of Notification No. 69/2011, on import of Inverter Assembly. 6.4.3 In view of the above, the Applicant wishes to submit that w.r.t. the aforementioned comments of the port authorities, it defers only with the view of the P....
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.... Bangalore, the product imported by the Applicant is "Inverter Assembly" used in motor vehicles and hence the same is not "Electric Inverter", therefore, the same cannot be classified under CTH 8504 40 -10 and the same merits classification under the residuary entry, i.e., CTH 8504 40 90. This understanding is totally erroneous as the Port Commissioner, ACC Bangalore has determined the classification of the Inverter Assembly at eight-digit level based on the nomenclature adopted by the Applicant to describe the product under consideration rather than classification based on principal function of the product. 6.4.8 In the present case, the Applicant is importing an Inverter Assembly used in motor vehicles. This Inverter Assembly is capable of converting AC to DC and vice versa (please refer Annexure-I to the Customs Advance Ruling Application for details of the functioning of the Inverter Assembly). Thus, the Inverter Assembly performs the function of a static converter (electrical inverter) which are covered under CTH 8504. 6.4.9 Further, upon perusal of the entries under CTSH 8504 40, it is clear that the term "Electric Inverter" encompasses all kinds of electrical inverters....
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....s per GIR 1, classification of a product ought to be done based on the terms of heading. Hence, upon perusal of the entries under CTSH 8504 40, we are of the opinion that based on the terms of sub-heading under CTSH 8504 40, the Inverter Assembly is classifiable under CTH 8504 40 10 which covers "Electric Inverters" as the same is capable converting AC to DC and vice versa. 6.5.3 Without prejudice, reliance may also be placed on GIR 3(a) for classification Inverter Assembly imported by the Applicant. As per GIR 3(a), when there are two or more competing entries, the entry which provides the most specific description shall be preferred to the entry which providing a general description. Applying the principles of GIR 3(a) in the present case, upon perusal of entries at eight-digit level under CTSH 8504 40 it is clear that since CTH 8504 40 10 specifically covers "Electric Inverters" the same becomes a more specific entry as opposed to CTH 8504 40 90 which is a residuary entry. Hence, upon application of GIR 6 read with GIR 3(a), the Inverter Assembly imported by the Applicant merits classification under CTH 8504 40 10. 6.6 Accordingly, the contention of the Port Commissionerat....