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TaxTMI 
TaxTMI 
TaxTMI 
2026 (5) TMI 137
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.... their application has submitted as follows: 2.1 'SafeStore Auto' is an automated self-service locker system based on robotised solution, which allows 24/7, 365 days access and privacy. It combines next-generation automated technology and advanced customer identification features without compromising top-level security. SafeStore Auto allows the customer to enter into a room, access their personal locker, and exit - all without any external human intervention. Similar to how a person can enter into an ATM and withdraw money, the customers can access their lockers in a safe space which is completely automated. The customers will have access to this locker 24/7, 365 days a year. 2.2 Thus, the product plays a key role in a retail bank's self-service concept to increase service quality. It is used to store valuable items in a secure location. These items can include gold and other precious metals, jewellery, bonds, contracts and other important documents. Unlike traditional locker rooms, this system eliminates manual intervention, enhances security, and optimizes space utilization through automation. Further, customers can access it 24/7 and not merely during operatio....
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.... of the subject product delivers the locker to the Delivery Cube (Exit Unit) where the customer can access it. The customer uses his or her personal key to access the contents. f. Return: After use, the customer returns the locker. When the customer presses the on-screen "deposit" button the system automatically returns it to its secure location. 2.5 Import in form of Kit 2.5.1 Initial import: Initially, the subject product will be imported in unassembled form from Gunnebo Germany factory in the form of a Kit. The Kit will consist of all the various components of the product such as automatic robot system, lockers, delivery cubes, control software, cargo overhandling point, etc and is hereinafter referred to as "the Kit". The Kit will then be assembled in India to form the complete product. The image of the finished subject product has been reproduced below: All the components of the above kit are imported together, and only assembly procedures will be undertaken in India. Thus, no components shall be further worked upon in India, nor shall any components be procured locally. In future, the Kit will be imported with all components mentioned above, except lockers. ....
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....ssified as the finished, assembled article at the time of import. Classification of 'Kit' 3.5 The product will be imported in the form of a kit, comprising of all the various items included in, automatic robot system, lockers, delivery cubes, control software, cargo overhandling point, even nuts, screws, etc. These items will be then assembled in India to form the entire product. As stated above, the components will not be subject to any further working, and no parts will be procured locally in India. In the present case it is submitted that all the components of SafeStore Auto are imported in unassembled form for the convenience of packing, handling or transport. Further, for assembling the finished product, no component over and above what has been imported, is needed and merely assembly operations shall be undertaken. Thus, the Kit can rightly be considered to be import of the subject product in unassembled form and classification of the product shall be according to Rule 2(a) as the finished article only. Classification of 'Kit without locker' 3.6 The product will be imported in the form of a kit. All necessary components will be present in the impor....
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.... may incorporate key-operated or combination locks, the classification under Heading 8303 and Chapter 83 is due to its constituent material i.e. they are made of metal. 3.7.3 Therefore, it is submitted that the product being in the nature of complex machinery, cannot be classified under Heading 8303. Kit (without locker) is not classifiable under Heading 8303 3.7.4 As submitted even when imported with locker, the Kit is not classifiable under Heading 8303. Thus, it goes without saying that Kit (without locker) is definitely not classifiable under Heading 8303. Without locker, the product imported is nothing must a mechanical machinery which can be used for deposit and retrieval of goods. The goods so being retrieved etc need not be a locker and can be a wide variety of things. Thus, there is no basis to consider the imported product to be a locker under Heading 8303. 3.8 The product is classifiable under Heading 8479 as "machines and mechanical appliances having individual functions, not specified or included elsewhere" 3.8.1 SafeStore Auto is an automated locker system which provides self-service access to customers. Thus, the product is essentially a machine that h....
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....form the storage grid where boxes are placed. Sockets, and frames Sockets and frames provide mechanical support and precise alignment for smooth robotic operations. Cargo Active Overhanding Point It is a mechanized transfer or handover module used in Safe Store Auto. Acts as the interface point where the robotic retrieval unit hands over the selected locker box to the delivery mechanism (such as an exit unit or customer access point). Also, ensures secure and precise positioning of locker cassettes during transfer between different levels or conveyors in multi-tier storage systems. Thus, it is submitted that the product in question is a machine. Further, it fulfils the definition of "individual function" as it is capable of performing its function distinctly from and independently of any other machine. 3.8.3 In fact, the product is akin to a robot as it functions on the basis of programmed instructions and inputs, and it does not require any human assistance or intervention (other than the user's inputs who is using the robot for accessing their belongings). Various types of robots are covered under Chapter 84 and those robots which are not classifiable elsewh....
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....le to provide service 24/7 to the users. Further, it is not in the nature of other robots which are covered under different Headings of Chapter 84, thus classification under Heading 8479 is appropriate for the product. There is no other Heading in the Chapter which can be suitable for this product. 3.8.4 Further, Section Note 3 of Section XVI is concerned with classification of multi- function machines. The relevant portion is extracted below: 3 .- Unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole and other machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function. The same states that, when a machine is capable of performing multiple functions, it will be classified as performing the principal function. The reason any person will use SafeStore Auto is for its automated retrieval mechanism. That is the key feature of the-imported product. Thus, when the whole emphasis of the product is on its automatic nature it shows that the prin....
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.... 5. A hearing was held on 01.12.2025 at 12:00 PM. Shri Srinidhi Ganeshan, Advocate has appeared online for the hearing and reiterated the contention submitted with the application that the subject goods are "Automatic Safe Deposit and Retrieval System. It is based on robotized solution and allows 27X7, 365 days service with easy access and privacy. It combines next generation automation technology, advanced customer identification features without compromising security. The system allows the customers to enter the room to access their personal locker and operate it with multi-level security comprising card-authentication, biometric authentication, PIN based authentication and manual key. The such locker or safe is attached with robotic system with facilitate to deliver the locker at designated exit/delivery unit. Sher submitted that the applicant intends to import the whole system (with or without safe) in CKD condition and the said automatic safe deposit and retrieval system merit classification under CTH 8479, in terms of Rule 2(a) and Section note 3 to the Section XVI. The principal function of the device system is to provide automate safe deposit and retrieval. She relied upon....
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....e storage of valuable items such as gold and precious metals, jewellery, bonds, contracts, and other important documents. Safe deposit box systems come in two categories: conventional, mechanical lockers; and fully automated lockers based on robot technology. While the fully automated system enables customers to access their safety deposit box at any time and without the need of staff assistance, the conventional solution is usually only accessible during bank opening hours. However, the integration of high-security electronic locks and automated user authentication can enable 24/7 self-service access also to conventional locker facilities. From the website of the manufacturer https://www.gunnebosafestorage.com/products/safestore-auto-midi/ it is observed that the subject goods are Automated safe deposit locker system. Customers have access to a secure room with a terminal where a robotised system delivers the customer's deposit box from the vault. Both the secure room and terminal use one or more identification methods (cards, camera, biometrics etc.) to verify the customer. When the customer is finished, the deposit box is returned to the vault by the robot. Combined with ....
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.... one closed end and one open end threaded to secure. a screw type closure, the portion below the threaded end being intended to be expanded to a desired size and shape). Semi manufacturers not yet having the essential shape of the finished articles (such as is generally the case with bars, discs, tubes, etc.) are not regarded as "blanks". (III) In view of the scope of the headings of Sections I to VI, this part of the Rules does not normally apply to goods of these Sections. (IV) Several cases covered by the Rule are cited in the General Explanatory Notes to Sections or Chapters (e.g., Section XVI, and Chapters 61, 62, 86, 87 ana 90). RULE 2 (a) (Articles presented unassembled or disassembled) (V) The second part of Rule 2 (a) provides that complete or finished articles presented unassembled or disassembled are to be classified in the same heading as the assembled article. When goods are so presented, it is usually for reasons such as requirements or convenience of packing, handling or transport. (VI) This Rule also applies to incomplete or unfinished articles presented unassembled or disassembled provided that they are to be treat....
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....machines merit classification on principal function. The reason any person will use SafeStore Auto is for its automated retrieval mechanism. That is the key feature of the imported product. Thus, when the whole emphasis of the product is on its automatic nature it shows that the principal function of the product is its automated functioning. Thus, the product is rightly classifiable under Heading 8479. The relevant portion of Heading 8479 from the Tariff is extracted below: 8479 MACHINES AND MECHANICAL APPLIANCES HAVING INDIVIDUAL FUNCTIONS, NOT SPECIFIED OR INCLUDED ELSEWHERE IN THIS CHAPTER 84791000 - Machinery for public works, building or the like 847920 - Machinery for the extraction or preparation of animal or fixed vegetable or microbial fats or oils **** 84793000 - Presses for the manufacture of particle board or fibre building board of wood or other ligneous materials and other machinery for treating wood or cork 84794000 - Rope or cable-making machines 84795000 - Industrial robots, not elsewhere specified or included 84796000 - Evaporative air coolers - Passenger boarding bridges ....
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.... not play an integral and inseparable part in the operation of such machine, appliance or entity. The relevant portion of the HSN Explanatory Notes to Heading 8479 regarding robots is extracted below: (7) Industrial robots for multiple uses. Industrial robots are automatic machines which can be programmed to carry out repeatedly a cycle of movements. By the use of sensors, industrial robots are able to acquire information about the field in which they operate and to analyse the information thus obtained to be able to adapt their pattern of activity to variations in their field of operation. Industrial robots may consist of an articulated structure comparable to that of the human arm, mounted on a base in a horizontal or vertical position, and having at its extremity a mobile holder for the toolholder (so-called vertical robots). They may also consist of a rectilinear structure often moving on a vertical axis of which the holder forms the terminal part of the operating mechanism often moving on a horizontal axis (horizontal robots). These robots could equally be placed on a beam (beam robots). The different parts of the structure are activated by electr....
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....eding 75 mm provided that the width of the wheel or tyre fitted thereto is less than 30 mm. GENERAL Whereas in Chapters 73 to 76 and 78 to 81 articles are classified according to a specific metal, this Chapter, like Chapter 82, covers certain particular classes of goods irrespective of the base metal of which they are composed. In general, parts of base metal are to be classified with their parent articles (see Chapter Note 1). However, the Chapter does not cover springs (even if specialised for locks, etc.), chains, cables, nuts, bolts, screws or nails; these goods are classified in the appropriate headings of Chapters 73 to 76 and 78 to 81 (see Note 2 to Section XV and Note 1 to this Chapter). Heading 8303 covers safety deposit lockers. Relevant portion of the HSN Explanatory Notes to Heading 8303 is extracted below: 83.03 - Armoured or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, of base metal. This heading covers containers and strong-room doors designed for securing valuables, jewels, documents, etc., against theft and fire. Safes and strong-boxes of this ....
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....bot" as claimed by the applicant. The applicant's interpretation has been misplaced. It is the safe deposit boxes/lockers that give the essential character to the subject goods. If not so, then the whole point of security by means of biometric, PIN and memory card will be worthless. The automated robotic system is a part of subject goods and if imported as standalone then only merit classification under CTH 84795000 as industrial robot not elsewhere specified or included. The automatic retrieval and advance customer identification are mere technical upgrade only for 24/7 access like ATM with which customers deposit, draw and transfer money and see the balances of their accounts without direct contact with bank personnel but the essential function is safe storage of valuable goods in safe deposit boxes/lockers. The subject goods as a whole mainly consists of shelf walls, cargo wall splitting, sockets and frames, cargo active overheating point and automatic robot system etc. The subject goods can be considered as composite machine and as per GRI Rule 3(b) which is read as: "(b) Mixtures, composite goods consisting of different materials or made up of different components....
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.... is the main attribute of such a product. The glass fiber mat when impregnated gives stiffness which helps in the manufactures of roofs, partitions etc, in the context of an insulation paper which is a composite of plastic and paper, the item will fall under Heading 39.01/06 of the previous Customs Tariff Act since plastic gives higher degree of insulation quality. Rule 3(b) requires classification based on the material which gives it the essential characteristics. This is the test of essentiality; The effect of the tariff schedule is to classify the products under different heads according to the character of the product. In interpreting a tariff entry. Rules for the Interpretation are helpful, particularly in cases of composite goods." Another important aspect of essential character is linked to the primary function of the goods. The Hon'ble Delhi Tribunal while determining the classification of a portfolio [containing a watch and a calculator] in Gift and Time Products v. Commissioner of Central Excise [1999 (107) E.L.T. 707], observed that even though certain components like the watch and calculator have their own use and utility, when combined with the portfolio, ....
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.... The HSN EN to the heading 8479 regarding industrial robot stress upon various Uses like, welding, painting, handling loading and unloading, cutting, assembling, metal trimming etc are such work replacing human task. These all are for meant for material handling, processing and management. The other industrial robots, specifically designed to perform a specific function; are to be classified under other heading other than 8479. But in the instant case as the applicant themselves contended that main function of the subject goods is primarily automated self-service locker system with privacy, safety and security enabled by automated technology. Industrial robots are mainly used to material management, assembling, welding, painting, packing, inspection, cutting and drilling, working in hazardous environment which may yield higher productivity, better accuracy, cut labour cost, reduce human risk or even work with 24/7 operation capabilities. In the instant case, the nature and uses of the Subject goods are different which is heavily inclined towards privacy, safety, security of personal belongings viz - Valuables gold, other precious metal and jewellery Bonds, Contracts, docum....
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....riff is extracted below: 8479 MACHINES AND MECHANICAL APPLIANCES HAVING INDIVIDUAL FUNCTIONS, NOT SPECIFIED OR INCLUDED ELSEWHERE IN THIS CHAPTER 84791000 - Machinery for public works, building or the like 847920 - Machinery for the extraction or preparation of animal or fixed vegetable or microbial fats or oils **** 84793000 - Presses for the manufacture of particle board or fibre building board of wood or other ligneous materials and other machinery for treating wood or cork 84794000 - Rope or cable-making machines 84795000 - Industrial robots, not elsewhere specified or included 84796000 - Evaporative air coolers - Passenger boarding bridges **** - Other machines and mechanical appliances 847989 **** -- Other **** --- Other 84798992 ---- Briquetting plant and machinery intended for manufacture of briquettes from agricultural and municipal waste 84798999 ---- Other 847990 - Parts 84799090 --- Other Relevant portion of the HSN Explanatory Notes to Heading 8479 is extracted below: This heading is restricted to machine....
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....Industrial Robots are covered under heading 84795000. Therefore, Robot is classifiable under CTI 84795000. 6.6.2 Shelf Troughs are used to create pathways across the structure to enable the robot to move to different boxes. It is specifically designed for an industrial robot to enable it move across the structure. Therefore, the shelf troughs are nothing but the parts/accessories of the Robot and the same is classifiable under CTI 84799090 as parts. 6.6.3 Shelf walls, sockets and frames are used to set up the structure on which boxes will be affixed. These shelf; sockets and frames are made of steel. CTH 7307 covers tube or pipe fittings (for example, elbow, couplings, sleeves), of iron or steel. The HSN explanatory notes of CTH 7307 provides that: This heading covers fittings of iron or steel, mainly used for connecting the bores of two tubes together, or for connecting a tube to some other apparatus, or for closing the tube aperture. This heading does not however cover articles used for installing pipes and tubes but which do not form an integral part of the bore (e.g., hangers, stays and similar supports which merely fix or support the tubes and pipes on walls, cl....
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....They are usually made up from bars, rods, tubes, angles, shapes, sections, sheets, plates, wide flats including so called universal plates, hoop, strip, forgings or castings, by riveting, bolting, welding, etc. Such structures sometimes incorporate products of other headings such as panels of woven wire or expanded metal of heading 73.14' Parts of structures include clamps and other devices specially designed for assembling metal structural elements of round cross-section (tubular or other). These devices usually have protuberances with tapped holes in which screws are inserted, at the time of assembly, to fix the clamps to the tubing. Apart from the structures and parts of structures mentioned in the heading, the heading also includes products such as: Pit head frames and superstructures; adjustable or telescopic props, tubular props, extensible coffering beams, tubular scaffolding and similar equipment; sluice gates, piers, jetties and marine moles; lighthouse superstructures: masts. gangways, rails, bulkheads, etc., for ships; balconies and verandahs: shutters, gates, sliding doors; assembled railings and fencing; level crossing gates and similar barriers; frameworks for gre....
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....ely machine that allow users to interact and have weighing mechanism, safety system and sensors. Since, the delivery cube have both mechanical and electronic processing and there is no specific heading provided in the tariff. Therefore, the delivery cube merits classification under CTH 8479, more specifically under CTI 84798999 as other machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter 84 as the delivery cubes satisfy the conditions of heading 8479 which are as under: This heading is restricted to machinery having individual functions, which : (a) Is not excluded from this Chapter by the operation of any Section or Chapter Note. and (b) Is not covered more specifically by a heading in any other Chapter of the Nomenclature. and (c) Cannot be classified in any other particular heading of this Chapter since : (i) No other heading covers it by reference to its method of functioning, description or type. and (ii) No other heading covers it by reference to its use or to the industry in which it is employed. or (iii) It could fall equally well into two (or more)....