TaxTMI 
TaxTMI 
2026 (7) TMI 1552
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....Serial No. 173/2025-26. The applicant proposes import of a new technology of the 'infotainment system/multi-media system' used in automobile, which would be in the form of semi-finished goods, i.e., 'Display Closing Assy' capable of displaying the information related to multi-media system/infotainment system of car and information related to car function like speedometer, fuel gauge etc which are to be fitted in the dashboard of an automobile, and requested for ruling on: i. classification of goods under the Customs Tariff Act, 1975; ii. applicability of a notification issued under sub-section (1) of section 25 of the Customs Act, 1962, having a bearing on the rate of duty. 1.1. The applicant in their application, submitted as follows: DETAIL ABOUT THE COMPANY - 1.2. Continental Automotive Component (India) Private Limited (hereinafter referred to as "Continental India" or "the Company" of the "Applicant") is a private limited company having its registered office at "13th Floor, South Gate, Plot #1, Survey No. 17,18,19 & 20, Veersandra Village, Hosur Main Road, Attibele Hobli. Anekal Taluk, Bengaluru, Karnataka 560100, India". 1.3. The ....
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....hich will display various information related to various car functions like navigation, audio and video control unit, speedometer, fuel gauge etc. 1.9. Further, owing to the technological advancement, the 'Display Closing Assy' which is a multi- media unit has the following applications which are inter alia as follow - 1. Audio & Media Control - Manages radio, Bluetooth, USB, and streaming audio. 2. Navigation & Maps - Provides GPS-based route guidance, real-time traffic updates, and points of interest. 3. Connectivity & Communication - Enables smartphone integration (Apple CarPlay, Android Auto), hands-free calling, and voice commands. 4. Vehicle Settings & Controls - Adjusts climate control, lighting, driver profiles, and other comfort features. 5. Display of Camera Feeds - Shows rear-view, 360° or parking camera visuals. 6. OTA & System Updates - Some systems support over-the-air updates for software and navigation maps. 7. Integration with ADAS - Displays alerts like lane departure, collision warnings, and adaptive cruise information. 8. Speed & RPM Display - Shows vehicle speed (speedometer)....
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.... Details 1 Cover Glass This is made of Soda Lime and protects other parts (such as the Display) as well as gives a good aesthetic appeal when mounted in a Car Dashboard. 2 FDC SEG LCD Assy (ICV) 6Non EU(12,3 "Seg 14,2 "TFT) CID TFT LCD(10. 25") The Displays, with Seg LCD / / TFT / TFT LCD denoting the technology of the Display. Displays are used to show the relevant information (such as speed, fuel level, infotainment details, climate control details etc.) to the car users. TFT LCD is capable of displaying information mentioned in Point no 1 to 7 of Para H whereas SEG LCD is further worked upon in India to display remaining functions. 3 PCB The 'Display Closing Assy' comes with the PCB attached to the TFT LCD from the display manufacturer. 4 Glue EA3838 Base Glue EA3838 Catalyst Adhesives used to attach the Frame Assy with the Display Closing Assy'. 5 Frame Assy Plastic injection molded parts used to hold the 'Display Closing Assy' on the one side as well as to support the PCB and other parts on the other side. It also helps transmit light appropriately from the LEDs (which are on the PCB) onto the Displays. ....
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....as to why customs tariff heading "8524.91" or "8527.29" is the most appropriate classification for the goods to be imported. Relevant applicable provisions 1.21. The Applicant wishes to seek an advance ruling on the classification of the above-mentioned products i.e. "Display Closing Assy" under the appropriate Tariff under the First Schedule to the Customs Tariff Act 1975. The detail of the specification of the said products have already been detailed out in the above paras. 1.22. It is submitted that the Customs duty is charged on import of goods into India under the provisions of the Customs Act, 1962 ('Customs Act') and at the rate specified in the schedule to the Customs Tariff Act, 1975 ('Customs Tariff Act') on the value as prescribed under the provisions of the Customs Act and Customs Valuation (Determination of value of imported goods) Rules, 2007 ('Customs Valuation Rules'). 1.23. Further, as per the clearance process, the importer-on-record files Bill of Entry consignment wise for goods mentioned in the relevant invoice and the packing list. Typically, goods, as mentioned in the Bill of Entry, are assessed to Customs duty individually ....
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....to be preferred (i.e., latter the better). iv. Rule 4 provides that if the classification is not possible by any of the aforesaid rules 1, 2, and 3, then it should be classified under the heading appropriate to goods to which they are most akin. v. Rules 5 and 6 are not relevant to this submission and therefore, the same are not discussed. 1.25. Basis the above-mentioned Interpretation Rules, the detailed submissions against the proposed HSN under which the 'Display Closing Assy' may merit classification are provided below in the sequential manner. Part I Submission with respect to classification under CTH 8524.9190 i.e., 'Other' which cover flat panel display of LCD, with driver and control circuit - 1.26. Before going into the merits of the submissions with respect to the CTH 8524, it would be pertinent to extract the respective CTH and the same is inter alia as follow- 8524 FLAT PANEL DISPLAY MODULES, WHETHER OR NOT INCORPORATING TOUCH-SENSITIVE SCREENS - Without drivers or control circuits : 8524 11 -- Of liquid crystals : 8524 11 10 --- For the goods of sub-heading 8471 30 or 8471 41 8524 ....
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.... form. Flat panel display modules may incorporate additional elements, including those necessary for receiving video signals and the allocation of those signals to pixels on the display. However, heading 85.24 does not include display modules which are equipped with components for converting video signals (e.g., a scaler IC, decoder IC or application processer) or have otherwise assumed the character of goods of other headings." 1.31. In addition to above, said heading also provide that "For the classification of flat panel display modules defined in this Note, heading 85.24 shall take precedence over any other heading in the Nomenclature." 1.32. Given the above, it is imperative to place reliance on the Explanatory Note to Heading 8524 with respect to the "Flat panel display modules with drivers or control circuits" which provides that- "(2) Flat panel display modules with drivers or control circuits: Drivers or control units are added to 'cells' of item (1). The modules may contain drivers that receive video signals or other data (e.g., text, images, ADP signals, or other graphical data) and switch individual pixels of displays (generally consisting of driv....
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....y other heading in the nomenclature. Accordingly, the Display Closing Assembly which is the integrated LCD flat panel display module should be covered under this heading. However, the only exception is that the LCD display should not have assumed the characteristic of the goods of other heading. 1.39. Further to derive at 8-digit classification of goods as provided under the Customs Tariff Act 1975, it is pertinent to delve into the feature / principal function of the 'Display Closing Assembly' imported by the Company. 1.40. In this regard, the Display Closing Assembly at the time of import is capable of performing functions mentioned under Point no 1 to 7 of Para H on attaching the post testing and a power source is attached to it. Further, after undertaking certain manufacturing process in India, additional functions mentioned in Point no 8 to 13 under Para H is added to the 'Display Closing Assy' like displaying information related to car functioning like speedometer, fuel gauge etc. 1.41. The current product is a liquid crystal display module with drivers attached and touch sensitive in nature. Therefore, for the same, the competent / appropriate classi....
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.... 8528 MONITORS AND PROJECTORS, NOT INCORPORATING TELEVISION RECEPTION APPARATUS, RECEPTION APPARATUS FOR TELEVISION, WHETHER OR NOT INCORPORATING RADIO- BROADCASTRECEIVERS OR SOUND OR VIDEO RECORDING OR REPRODUCING APPARATUS - Cathode-ray tube monitors: 8528 42 00 -- Capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471 - Other monitors: 8528 52 00 -- Capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471 - Projectors: 8528 62 00 -- Capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471 1.46. From the above, it can be seen that `Other Monitors' which are capable of directly connecting to and designed for use with an ADP of Heading 8471 merit classification under CTII 8528 52. 1.47. Further, on conjoint reading of Entry No., 17 and 29 of Notification No. 24/2005 - Customs dated 01 March 2005 and CTH 8528 5200 supra, it can be construed that - 'Liquid Crystal Display if capable of to be used with all goods of a kind solely or pr....
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....of receiving / accepting a signal from the central processing unit of an automatic data processing machine and provide a graphical presentation of the data processed. The said explanatory notes further provide the monitors of this group may be characterized by the following features - i. They usually display signals of graphics adaptors (monochrome or colour) which are integrated in the central processing unit of the automatic data processing machine; ii. They do not incorporate a channel selector or video tuner; iii. They are fitted with connectors characteristic of data processing systems (e.g., RS- 232C interface, DIN, D-SUB, VGA, DVI, HDMI or DP (display port) connectors); iv. The viewable image size of these monitors does not generally exceed 76 cm (30 inches); v. They have a display pitch size (usually smaller than 0.3 mm) suitable for close proximity viewing; vi. They may have an audio circuit and built-in speakers (generally, 2 watts or less in total); vii. They usually have control buttons situated in the front panel; viii. They usually cannot be operated by a remote control; ix. They may inco....
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....ctly connecting to, and designed for use with, an automatic data processing machine of heading 8471. It usually has control buttons situated in the front panel, and they may utilise wireless communication protocol to display data from an automatic data processing machine of heading 8471. The monitors have features such as touchscreens, specific connectors, and are tailored for integration into the vehicle's dashboard or console. That in the said scenario, it has been held that the monitor carrying such specification for use in automobile and is capable of getting connected with the ADP like mobile phones and tablets, or any other Bluetooth / usb media merit classification under CTH 8528 52 i.e. 'Capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471', For ease of reference, the copy of ruling is attached. 1.59. Similarly in the present case also, the finished product merit classification under CTII 8528 5200 i.e., "Other Monitor' which is capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471 (i.e. in the present case with mobile phones ....
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.... heading 8527 covers "Reception Apparatus For Radio- Broadcasting Whether Or Not Combined, In The Same Housing, With Sound Recording Or Reproducing Apparatus Or A Clock". It covers radio broadcast receivers capable of operating without an external source of power. 1.64. It is further pertinent to mention that as per the Explanatory Note to Heading 8527 (issued by the WCO), the group / Heading 8527 categorically covers the following - "This group includes : i. Domestic radio receivers of all kinds (table models, consoles, receivers for mounting in furniture, walls, etc., portable models, receivers, whether or not combined, in the same housing, with sound recording or reproducing apparatus or a clock). ii. Car radio receivers. iii. Separately presented reception apparatus for incorporation in relay apparatus of heading 85.25. iv. Pocket-size radio cassette-players (see Subheading Note 4 to this Chapter). v. Stereo systems (hi-fi systems) containing a radio receiver, put up in sets for retail sale, consisting of modular units in their own separate housing, e.g., in combination with a CD player, a cassette recorder, an amplifier ....
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....logical advancements in the market, there has been a growing demand for integrated solutions that combine multiple functionalities within a single unit. Specifically, the market has seen the emergence of a requirement for a combined housing that incorporates the complete functionalities of car for display purpose under the same housing. The said functionalities include navigation, audio-video control unit, speedometer, fuel gauge etc. under one panel (detailed functionalities has already been explained under Para H of Statement of Facts) 1.70. This progression has resulted in the development of multi-functional display unit in cars which performs multiple functions such as navigation, multimedia playback, smartphone integration, voice control, speedometer, trip information, etc., greatly enhancing the in-car experience for users. 1.71. This innovation not only enhances the dashboard design but also offers enhanced convenience and functionality, reflecting the ongoing evolution of automotive technology. 1.72. Further, for reference, a pictorial representation to distinguish the old model of the car infotainment system viz a viz current new technology of the car infotainment....
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....foreseen when the policy or tariff was created. The relevant para from the judgment is quoted below for ease of reference - "4. We do not think that we can put it better. Progress cannot be stifled by an over-rigid interpretation of Import Policy or Customs Tariff. Both must be read as they stand on the date of importation and whatever is reasonably covered thereby must be allowed to be imported regardless of the fact that it was not in existence or even contemplated when the policy or tariff was formulated." 1.78. Reliance is also placed in the matter of the Hon'ble Delhi High Court in its recent decision in Vivo Mobile India Pvt. Ltd. v. Customs Authority for Advance Rulings 2025 (392) E.L.T. 489 (Del.) has clarified that change in technology does not imply change in classification of the product because it is primary identity of the product which is the basis of the classification and not the technology on the basis of which the product operates. The relevant observations of the Hon'ble High Court are reproduced below for ease of reference; "47. The appellant's contentions are premised on the presence of technical components within the product, n....
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.... to be updation in the HS code schedule capturing the appropriate HS code classification . 1.82. Accordingly, considering the multifunctional usage of the final manufactured product as well as the functions performed by the Display Closing Assy it merits classification under the CTH 8524.91 or 8527.29 along with the specific exemption available under the Notification No. 24/2005-Customs dated 01 March 2005. Part-V HSN Classification of the 'Display Closing Assy' as per the General Rule of Interpretation = 1.83. The general rules for the interpretation of the Customs Tariff lay down the principles for the classification of the goods under the Customs Tariff Act. That Rules 1 to 4 of Interpretational Rules are related and must be applied in sequence. Rules 5 and 6 stand on their own to be applied as needed. Accordingly, the application of the Interpretation Rule to determine the classification of the 'Display Closing Assy' is as given below - GIR Application for 8524.91 Application for 8527.29 * Rule 1 provides that classification shall be determined basis the terms of the heading along with Section notes and Chapter notes while classifyi....
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....must be determined based on the manner in which the goods are presented to the customs authorities. * Consequently, the imported product should be classified as an infotainment system unit under CTH 8527.29. * Rule 2(b) relates to the classification of Mixture or Combinations. However, it is not applicable for the classification of goods consisting of more than one material substance and the same shall be according to the principles contained in Rule 3 * Since the classification of the 'Display Closing Assy' has already been determined under the above- mentioned Rule 1 thus there exists no needs to take resort of Rule 2. * This rule will not be applicable in the present matter as there is no mixture or combination of items * Rule 3 is important. and it has three (3) parts: Rule 3(a) - The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods or to part only of the items in a set, those headings are to be regarded as equally specific in relation to those goods, eve....
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....el contained control circuit but does not have the IC decoder option to decode the encoded video signal. With respect to the CTH 8527.29 1.85. In addition to the above, it is submitted that the judicial decision interpreting the scope of 8527.29 are a relevant guide in order to appreciate the scope and contents of this heading. In view of the Applicant, the relevant decision will confirm our understanding of this heading and therefore it is expediate to appreciate these judgements - 1.86. In Bosch Ltd vs The Commissioner of Customs, (2024) 21 Centax 27 (Tri .- Bang), the Hon'ble CESTAT, Bangalore has held that multifunctional device, capable of calling, listening to music, Bluetooth connectivity, and navigation, among other features should be classified under HSN 8527 2900. The Tribunal held that "The classification under Tariff Item 8527 29 00 was justified because all functions of the device were equally important, and there was no principal function." In addition, the Hon'ble CESTAT has also observed as under "The literature clearly establishes that it is a multifunctional device which is used as a device to make call, listen to music, use as a Bl....
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....C.)]" Part-VII Summary of discussion of legal position 1.91. In this regard, the Applicant would like to mention that the goods intended to be imported is the 'Display Closing Assy', which at the time of import is capable of performing functions mentioned under Point no 1 to 7 of Para H of the Statement of Facts on post testing and provided a power source is attached to it. 1.92. Further, after undertaking certain manufacturing process in India, the complete housing is capable of working as a multi-functional unit inside a car with capabilities such as navigation, fuel gauge, audio & media control, parking camera visual, speedometer etc. 1.93. Given the above, the Applicant wants to understand the possible Harmonized System of Nomenclature ("HSN") classification for the semi-finished goods i.e., 'Display Closing Assy' which is intended to be imported by the Applicant to manufacture the final product which is fitted into the car dashboard for displaying various information as submitted supra. Parameters Reasons for Classification under 8524.91 Reasons for Classification under 8527.29 Reliance on the Section Notes and Explanatory Notes....
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....ing without an external source of power, of a kind used in motor vehicles' Reliance on Judicial Rulings * The Applicant relies on the ruling of Clarion India Pvt. Ltd. [2025(01) LCX0259(AAR)]. where the Advance Ruling Authority, New Delhi held that LCD panels used in motor vehicle infotainment systems merit classification under CTH 8524. * The Applicant would like to place reliance in the matter of Bosch Ltd. vs Commissioner of Customs [(2024) 21 Centax 27 (Tri .- Bang)], wherein the Hon'ble CESTAT, Bangalore held that a multifunctional device-capable of calling, playing music, Bluetooth connectivity, and navigation- merits classification under HSN 8527 2900, as all functions were equally important and no principal function could be identified. Further, emphasizing the fact that such multifunctional devices used in motor vehicles and powered externally fall squarely under CTH 8527. This decision was subsequently affirmed by the Apex Court. Applicability of Exemption Exemption available under Serial No. 29 read with Serial No. 17 of Notification 24/2005 dated 01 March 2005. No specific exemption Relevance of HS code classification for manufactured produc....
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....ty of proviso (1) of section 28-I (2) of the Customs Act, 1962 regarding the question raised in the application. As per records available in the Section, no such case of the applicant is pending with any officer of the Customs, other Appellate Tribunal or any Court as per proviso of Section 28(I) (2) of Customs Act, 1962. 2.1.3 (iii) Specify whether the claim of the applicant regarding the nature of activity, i.e. it is ongoing/proposed is correct. As per available records, the import of 'Display Closing Assy' has not been commenced 2.1.4 (iv)Comments on merit of the question raised in the application, along with all materials in support thereof. Nature of activity proposed to be undertaken: "Display Closing Assy and classification thereof under Customs Tariff Act, 1975.' Question of law or fact: Question 1: Whether "Display closing Assy" (hereinafter referred to as 'subject product') is classifiable under Customs Tariff heading 8524.91 or 8527.29of the First Schedule to the Customs Tariff Act, 1975 (hereinafter referred to as the 'Tariff Act")? Answer- The "Display Closing Assy" is not classifiable under CTH 8....
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....multi-media unit has the following applications which are inter alia as follow - 1. Audio & Media Control - Manages radio, Bluetooth, USB, and streaming audio. 2. Navigation & Maps - Provides GPS-based route guidance, real-time traffic updates, and points of interest. 3. Connectivity & Communication - Enables smartphone integration (Apple CarPlay, Android Auto), hands-free calling, and voice commands. 4. Vehicle Settings & Controls - Adjusts climate control, lighting, driver profiles, and other comfort features. 5. Display of Camera Feeds - Shows rear-view, 360° or parking camera visuals. 6. OTA & System Updates - Some systems support over-the-air updates for software and navigation maps. 7. Integration with ADAS - Displays alerts like lane departure, collision warnings, and adaptive cruise information. 8. Speed & RPM Display - Shows vehicle speed (speedometer) and engine revolutions per minute (tachometer). 9. Fuel & Temperature Monitoring - Displays fuel level, engine coolant temperature, and sometimes oil temperature. 10. Warning Indicators - Lights and alerts for battery, engine check,....
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....4. The functional integration present here exceeds the scope of a simple 8524 display module. c) The Product is Composite and Not Merely a Display. The applicant itself admits the item consists of Cover Glass, FDC SEG LCD/TFT, PCB, Glue, and a Frame Assy. A mere flat panel display module would not include automotive-specific plastic housing and mounting frames. These structural components are integral parts of a motor vehicle instrument cluster/dashboard assembly, placing the good firmly in 8708 territory. d) The Applicant's Own Description Contradicts 8524 Classification. The applicant repeatedly describes the product as displaying "information related to car functions like speedometer, fuel gauge, navigation, audio/video control." These are precisely the functions of an instrument cluster or infotainment display part, which are classifiable as motor vehicle parts under 8708, consistent with the principle in Imperial Motor Stores (where instrument clusters were held to be 8708 parts). II. Rebuttal to the Argument that the Product Merits Classification under CTH 8527 (Multimedia/Infotainment Reception Apparatus) Importer's claim: Alternatively, the p....
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....ed Exclusively for Motor Vehicles - Rule 1 Read with Section XVII Chapter Notes The Display Closing Assy is designed, dimensioned, and sold solely for fitment into the dashboards of automobiles. It has no alternative or general-purpose commercial use. Under Rule 1 read with the Chapter Notes to Section XVII, parts and accessories exclusively or principally used with motor vehicles are to be classified under 8708. The governing legal framework is the three-condition test laid down in the HSN Explanatory Note (III) to Section XVII, which was extracted and applied verbatim by the Principal Bench, CESTAT New Delhi in M/s Continental Automotive Brake Systems India Private Limited vs. Commissioner of Customs, ICD, Patparganj [Final Order No. 55365-55440/2024 dated 19.03.2024]. The HSN Note reads as follows: "It should, however, be noted that these headings apply only to those parts or accessories which comply with all three of the following conditions: (a) They must not be excluded by the terms of Note 2 of this Section; and (b) They must be suitable for use solely or principally with the articles of Chapters 86 to 88; and (c....
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....completion it "is sold to Original Equipment Manufacturers / OEM's which fit this into the dashboard of the car." The product has no other commercial use whatsoever. The Tribunal in the Continental Automotive Brake Systems case confirmed this condition is satisfied where "the imported ECU were used only for automobiles and there is no evidence of any other use." On Condition (a), the Department anticipates that the applicant may contend that since the Display Closing Assy contains LCD, TFT screens, and PCB-being electrical/electronic components-it stands excluded from Section XVII by virtue of Section Note 2(f) or (g). This argument was conclusively rejected by the CESTAT Principal Bench in both the Continental Automotive Brake Systems case and M/s Mitsubishi Electric Automotive India Pvt. Ltd. vs. Commissioner of Customs [Final Order No. 58663-58722/2024]. The Tribunal held: "Merely because it is in the form of a PCB and other electronic components does not change it from a part of an automobile into an instrument or an apparatus." The Display Closing Assy, though containing PCB and LCD/TFT components, is in essence a composite automotive dashboard s....
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.... declarations: "The appellant itself has declared the nature of goods as 'ECU Automotive parts' in all its declarations and has been classifying them under CTI 8708 99 00." The present applicant cannot, in these circumstances, successfully contend before this Authority that an analogous electronic automotive sub-assembly imported by its own group entity for exclusive automotive fitment should be classified differently. The Tribunal's finding that "all the three conditions are met and ECU must be classified under CTI 8708 99 00" is directly applicable on facts and binding in principle on the present proceedings. C. Rule 3(b) - Essential Character Favours 8708 99 00 Even if any residual dispute remained between CTH 8524 and CTII 8708 (it is submitted none does, as Rule 1 read with Section XVII Notes resolves the matter), Rule 3(b) of the Interpretation Rules requires classification based on the component that gives the product its essential character. The essential character of the Display Closing Assy is not the generic LCD screen -- - which is a widely traded commodity component-but the automotive-specific integration of displ....
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....ter and heading. 4.1.3 In this regard and at the outset, the Applicant would like to strongly emphasize that Explanatory Note to CTH 8524 categorically provides that this Customs Tariff Heading ('CTH') take precedence over all other chapter for classification of flat panel display assembly which are with or without driver or control circuit and the same is read as "For the classification of flat panel display modules defined in this Note, heading 85.24 shall take precedence over any other heading in the Nomenclature." 4.1.4 Further, on bare reading of the definition of flat panel display module given under Chapter 85, it can be seen that flat panel display module can have additional elements attached to it. The relevant para is read as - "For the purposes of heading 85.24, "flat panel display modules" refer to devices or apparatus for the display of information, equipped at a minimum with a display screen, which are designed to be incorporated into articles of other headings prior to use. Display screens for flat panel display modules include, but are not limited to, those which are flat, curved, flexible, foldable or stretchable in form. Flat panel display modules ma....
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....me of import, and the department has failed to correctly appreciate the scope of the said explanatory note. 4.1.8 In addition to the above, it is imperative to mention that in the recent ruling pronounced by the Ld. Advance Ruling Authority, Delhi in the matter of Vivo Mobile India Pvt. Ltd., the Ld. Authority has classified the display assembly used in manufacturing of cellular mobile phone under CTH 8524 9220 i.e., Flat Panel Display Module basis its essential character and not under CTH 8517 7990 i.e. Parts of Cellular mobile phone which is the end use of the product. In the said matter, the display module was imported by the Applicant in which driver IC was attached to it which has the function of converting video signal and can decode and convert data signal into analogue video signals. That while classifying the said display unit under CTH 8524 9220, the Ld. Advance Ruling Authority held that - "4.9. I further observed that the emphasis in Note 7 is on the essential character of the goods as display modules, and not merely on their end use. The Note recognises that modern flat panel displays, particularly OLED and AMOLED displays, inherently require driver circuit....
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....es functional and suitable for use in a vehicle. This clearly shows that, at the time of import, the product is not an automobile part but has essential character of Flat Panel Display Module classified under CTH 8524 9190. The department has thus failed to properly examine the condition of the goods at the time of import, which is the relevant stage for classification. It is a settled principle that classification cannot be based on the end use of the imported goods, but must be determined on the basis of the condition and characteristics of the goods at the time of import. Accordingly, the essential character of the product remains that of a display module, and classification under Heading 8524 is justified. Department Rebuttal - The Clarion India Ruling is Distinguishable and Actually Supports 8708 Classification. The importer heavily relies on Clarion India Pvt. Ltd .. However, that case involved a bare LCD Panel lacking an IC decoder, navigation functionality, or radio capability. The present "Display Closing Assy" is a fully integrated assembly (TFT LCD, SEG LCD, PCB, Frame Assy) capable of displaying multi-media and vehicle instrument data upon import. Critically....
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....Thus, from the above it is evident that 'Display Closing Assy' in the present matter, is in principle similar to that of LCD Panel as discussed in the Clarion Ruling. 4.1.16 Further, in the ruling ultimately the bench upheld that the LCD panel used in infotainment system is classified under 8524 9190. The relevant extract is reproduced below: "From the above, it can be stated that a flat panel display module for motor vehicles (which is not integrated with other apparatus) would be classifiable under CTH 8524, rather than as a part of the finished product. In the present case, the LCD Panel satisfies the aforesaid conditions and hence. can be said to be flat panel display module due to the following reasons: i) The product is equipped with a display screen, and it utilises LCD technology to show the relevant information on the screen; ii) The product is designed to be incorporated into an infotainment system of motor vehicles prior to its use; iii) The product does not include any components for converting video signals; iv) The product is not specifically covered under any other heading." 4.1.17 Further, the department is ....
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....rence, the relevant portion from the Explanatory Note to Chapter 8524 is extracted verbatim below - "The articles of this heading are equipped at a minimum with a display screen utilizing liquid crystal display (LCD), organic light-emitting diodes (OLED), light-emitting diodes (LED) or other display technologies. .... .... .... .... This heading includes : (2) Flat panel display modules with drivers or control circuits: Drivers or control units are added to 'cells' of item (1). The modules may contain drivers that receive video signals or other data (e.g., text, images, ADP signals, or other graphical data) and switch individual pixels of displays (generally consisting of driver IC and PCB that connects video signals to driver IC) or control circuits of power supply for display modules or timing control. They might combine with backlight units (for LCDs) or frames (chassis)." 4.1.20 From the above, it is evident that Flat Panel Display Module can consist of other apparatus or instrument too. Accordingly, in the present matter, Display Closing Assy satisfy with the above definition as the display module in the present matter contain the....
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....heading for display apparatus, such as 8524, it cannot be classified under a general heading for vehicle parts like 8708. Note - Before proceeding further with Classification under CTH 8527, the Applicant humbly wishes to submit that as per the understanding of the Applicant, the product more suitably merit classification under CTH 8524, however, since the product is also capable of performing few functionalities at the time of import (upon mere testing and installation of software) an attempt to classify the same under CTH 8527 i.e. as Multimedia apparatus has also been made by the Applicant. Department Rebuttal - 4.1.24 II. Rebuttal to the Argument that the Product Merits Classification under CTH 8527 (Multimedia/Infotainment Reception Apparatus) Importer's claim: Alternatively, the product can be classified under 8527.29 as a radio broadcast receiver incorporating sound reproduction apparatus (multimedia/infotainment system). Counter-arguments: a) The Product Lacks Independent Radio Broadcast Reception Capability. CTH 8527 covers "Reception apparatus for radio-broadcasting." The importer has failed to establish that the "Display Closing Assy" co....
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....ms of displaying the data related to the infotainment system at the time of import. In this regard, it is to be noted that in the Bosch Ruling the product which was imported was described as 'Infotainment System' which had the following features at the time of import like AM/FM tuner, USB/SD/Pod, a UX audio input and DVD video output, Bluetooth, smartphone integration, GPS navigation, etc. That the said Infotainment system was switched on when ignition was given and switched off when the ignition of the vehicle is switched off and thus, it was considered as Multifunctional Device not capable of operating without external source of power of a kind used in motor vehicles. Further, the navigation function was available only if the device was equipped with the 'Navigation System' and this function was available when the SD card obtaining the map data was inserted. 4.1.27 Similarly, in the present matter, the Display Closing Assy, at the time of import capable of performing the various functions like Audio and Media Control, Navigation and Maps, smartphone integration, etc (as mentioned in Point no I to 7 of Para H of Statement of Facts in the Application). Further, a....
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....ing in India. A product that does not yet embody the complete functional characteristics of an infotainment unit cannot be classified as one. Applying GIR 2(a) is inappropriate because the "essential character" of a complete multimedia reception unit (signal reception and independent processing) is absent. 4.1.30 APPLICANT COMMENTS - The department's claim that the product is only a semi-finished sub-assembly is not correct. As per the General Rules for Interpretation, especially Rule 2(a), even an incomplete product must be classified as a complete product if it has the essential character of that product. In this case, the Display Closing Assembly already performs the key functions of a multimedia/radio reception system, such as allowing the user to control media, select radio options, and view the output. These are the functions of multimedia unit classified under CTH 8527.29 i.e. 'Other' to 'Radio-broadcast receiver. The fact that some additional features like speedometer or vehicle data are added later is not relevant, as these are only extra features and do not change the main character of the product. 4.1.31 Further, if the department's contention i....
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....ns LCD/TFT display, includes LCD Screen and printed circuit boards, and thereby performs display and interface functions. These features intrinsically place it within Chapter 85, which is explicitly excluded from being treated as "parts of automobile" under Section XVII. 4.1.35 Therefore, once the product is identifiable as an electronic display apparatus, it is automatically excluded, regardless of its use in a vehicle. 4.1.36 Further reliance sought to be placed by the Revenue on the decisions in M/s Continental Automotive Brake Systems India Private Limited vs. Commissioner of Customs [Final Order No. 55365-55440/2024] and M/s Mitsubishi Electric Automotive India Pvt. Ltd. vs. Commissioner of Customs [Final Order No. 58663-58722/2024] is, in principle, misconceived and devoid of any merits. This is owing to the reason that aforesaid decisions pertain to the classification of Electronic Control Units (ECUs) specifically designed and manufactured for exclusive use in automobiles. That without ECU, the power steering will not be able to function as it is used in automobiles with power steering, and it determines how much assistance is required to augment the steering effort o....
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....er 8524 (i.e., display/monitor categories), for which the Applicant has already provided sufficient explanation in the above paragraphs. Further, even the Explanatory Note to Heading 8524 begins with a "Notwithstanding" clause, meaning thereby that such heading takes precedence over other competing headings, and even if such display units are designed for use with specific machines or systems (including automobiles), they will still be classified under Heading 8524 based on their independent function as display apparatus. 4.1.40 As per settled classification principles, a specific heading always prevails over a general heading (parts of automobile being a residual/general category). Therefore, when a product is clearly covered under a specific heading like display apparatus, it cannot be pushed into "parts" classification merely because of its use. Hence, Condition (c) is not satisfied. Prayer In view of the above, it is prayed that this Hon'ble Authority may be pleased to - a) To admit the responses to the comments received from the Assistant Commissioner of Customs vide Letter dated 21 April 2026 b) To determine and declare that the goods (i.e....
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....output is transmitted back to the Display Closing Assembly for display and user interface purposes. 4.2.6 Resultantly, it is the said ECU which can be considered to be an ADP and thus can be closely correlated with Vehicle-Mounted Computers ('VMC') as classified and dealt in the matter of Honeywell International India Pvt Ltd. To substantiate this position, a comparative analysis of the ECU vis-à-vis Vehicle Mounted Computers, with reference to each of the ADP parameters prescribed under Note 6(A) to Chapter 84, is set out below - SI. No. Parameters of ADP (as per Note 6(A) of Chapter 84 for ADP) Complied by or not Vehicle Mounted Computers (as held by the Advance Ruling Authority) ECU 1 Ability to store programs and data They store and execute programs ECU also store software programs or run application logic. 2 Capability to be freely programmed They can be freely programmed ECU can be programmed by the user to perform data processing tasks. All programmable logic resides in the ECU or external ADP device 3 Ability to perform arithmetic operations They carry out arithmetic and logical operations ECU perform math....
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....bly Module' or 'Human-Machine Interface' (HMI) feature of the vehicle dashboard means it is not just a screen that shows information, but also a control panel that lets the user interact with the entire vehicle systems. It can receive inputs from the user, through touch, gesture, or voice, then convert these actions into electronic signals, and send them to the ECU. The ECU processes this information, performs the required actions, and then sends the information back to be shown or displayed on the Display Assembly or monitor. 4.2.13 Thus, the Display Assembly operates as a complete HMI system in the following manner which are inter alia as follow - * Receiving Input: The system receives inputs from users through touchscreen controls, physical buttons, voice commands, and connected devices. * Processing of Data received (Role of ECU): 4.2.14 The inputs so received are transmitted to the ECU, which performs processing of such input data. In this regard, it is to be noted that in the automobile, the ECU is the microprocessor-based computational core of the automotive electronic architecture. The role of ECU is to interprets commands, execu....
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....cting to and designed for use with an automatic data processing machine", thereby reinforcing classification under CTH 8528 rather than Heading 8471. Conclusion - 4.2.20 Based on the above submissions, the classification along with the exemption (reasoning for the exemption already explained in detail in the advance ruling application and for the sake of brevity the same is not repeated here) of the 'Display Closing Assembly' can be summarized as follows: 1. Classification of Display Closing Assembly Under CTH 8524 The Display Closing Assembly qualifies for classification under CTH 8524 9190 i.e., 'Other' which cover 'flat panel display of liquid crystal, having driver and control circuit attached to it. This category specifically encompasses flat panel LCD displays equipped with driver and control circuits, as detailed in the technical grounds of the Advance Ruling Application. 2. Eligibility for Notification No. 24/2005-Customs dated 1 March 2005 By virtue of classification under CTH 8524 9190, the Display Closing Assembly meets the criteria for exemption under Entry No. 29 of Notification No. 24/2005-Customs dated 1 M....
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....Following post-import manufacturing value addition in India, the assembly gains full functionality, enabling it to display comprehensive vehicle performance data, such as speedometer and tachometer readings, fuel and temperature monitoring, diagnostic warnings, and drive-mode indicators, ultimately functioning as a complete multi-media and driver information system for Original Equipment Manufacturers (OEMs). 5.3 As per the applicant's submission, the applications of this assembly include: i. Audio & Media Control: Manages radio, Bluetooth, USB, and streaming audio. ii. Navigation & Maps: Provides GPS-based route guidance, real-time traffic updates, and points of interest. iii. Connectivity & Communication: Enables smartphone integration (Apple CarPlay, Android Auto), hands-free calling, and voice commands. iv. Vehicle Settings & Controls: Adjusts climate control, lighting, driver profiles, and other comfort features. v. Display of Camera Feeds: Shows rear-view, 360º, or parking camera visuals. vi. OTA & System Updates: Supports over-the-air updates for software and navigation maps. vii. Integration with ADA....
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....at "classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes." 5.8 To ascertain the classification of the impugned goods, the following competing tariff headings require examination: Heading 8524 (flat panel display modules, whether or not incorporating touch- sensitive screens), Heading 8527 (reception apparatus for radio-broadcasting whether or not combined, in the same housing, with sound recording or reproducing apparatus or a clock) and Heading 8708 (parts and accessories of the motor vehicles of headings 8701 to 8705). The relevant entries of the Headings are as follows :- 8524 FLAT PANEL DISPLAY MODULES, WHETHER OR NOT INCORPORATING TOUCH-SENSITIVE SCREENS - Without drivers or control circuits : 8524 11 -- Of liquid crystals : . 8524 11 10 --- For the goods of sub-heading 8471 30 or 8471 41 8524 11 20 --- For the goods of sub-heading 8517 13 or 8517 14 8524 11 30 --- For the goods of sub-heading 8528 72 or 8528 73 8524 11 90 --- Other - Other : 8524 91 -- Of liquid crystals : 8524 91 10 --- For t....
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....rts thereof 8708 95 00 -- Safety airbags with inflater system; parts thereof 8708 99 00 -- Other 5.9 I note that Chapter 85 covers "Electrical machinery and equipment and parts thereof; sound recorders and reproducers, television image and sound recorders and reproducers, and parts and accessories of such articles" and Heading 8524 covers "flat panel display modules, whether or not incorporating touch-sensitive screens". Note 7 to Chapter 85 states as follows: 7. For the purposes of heading 8524, -flat panel display modules refer to devices or apparatus for the display of information, equipped at a minimum with a display screen, which are designed to be incorporated into articles of other headings prior to use. Display screens for flat panel display modules include, but are not limited to, those which are flat, curved, flexible, foldable or stretchable in form. Flat panel display modules may incorporate additional elements, including those necessary for receiving video signals and the allocation of those signals to pixels on the display. However, heading 8524 does not include display modules which are equipped with components for converting video signa....
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.... sub-assembly engineered exclusively for automotive dashboard integration. The product's design, characterized by specific connector interfaces and a structural plastic injection-moulded frame, confirms it is purpose-built for motor vehicle fitment, which places it outside the intended scope of Heading 8524. Furthermore, the Explanatory Notes to Heading 8524 clarify that display modules integrated into other apparatus are to be classified in the heading appropriate to the apparatus as a whole, rather than as a general display module. The applicant's reliance on the Clarion India Private Limited (Ruling No. CAAR/Del/Clarion/19/2025) ruling is misplaced, as that case involved a bare LCD panel, whereas the current assembly is a complex, integrated unit capable of displaying vehicle-specific instrument data and multimedia content. The presence of non-display components, such as the protective frame and mounting assembly, demonstrates that the item has transcended the definition of a simple display and has acquired the character of a dedicated automotive component. Because the assembly is explicitly designed to serve as an instrument cluster and infotainment interface, it fails ....
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....st reception and signal processing capabilities at the time of importation, it cannot be considered a complete "reception apparatus". The applicant's own submission confirms that critical functions such as vehicular diagnostics and instrument readings are only achieved after further processing in India, meaning the essential character of a finished infotainment system is absent at the time of import. Additionally, the reference to TPV Technology India Pvt. Ltd. Versus The Commissioner of Customs (Preventive) [ 2025 (394)) E.L.T. 231 (S.C.)] is irrelevant, as that case dealt with distinct audio-reproduction hardware that does not share the functional or structural characteristics of this dashboard display sub-assembly. Consequently, the item does not meet the functional criteria required for Heading 8527. Therefore, I reject the applicant's contention for classification under CTH 8527. 5.15 The applicant attempts to justify their classification claims by systematically applying the General Rules of Interpretation (GIR), asserting that Rule 1 is sufficient to establish classification under Heading 8524, while simultaneously invoking Rule 2(a) as a secondary justification f....
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....ethodical, a broader assessment of the product's purpose and configuration is necessary to ensure the classification aligns with the overall structure of the Customs Tariff. 5.17 I find that the most appropriate approach for determining the classification of the "Display Closing Assy" is to rely primarily on Rule 1 and Rule 3(a) of the General Rules of Interpretation (GIR), which provide the essential legal framework for resolving these competing claims. Rule 1 serves as the starting point, requiring that classification be determined by the terms of the headings read alongside the relevant Section and Chapter Notes; this foundation is necessary to assess whether the assembly qualifies as a general-purpose display or as an automotive component designed specifically for vehicle integration. When an item potentially falls under multiple headings, such as the electronic heading 8524 and the automotive parts heading 8708, Rule 3(a) provides the necessary mechanism for resolution by favoring the heading that offers the most specific description. Given that this assembly is engineered with specialized housing and mounting configurations tailored exclusively for a vehicle dashboard,....
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.... commercial application, a fact supported by the applicant's own project declarations. Regarding Condition (a), the tribunal's consistent interpretation confirms that the electronic nature of a part does not attract the exclusionary provisions of Section Note 2. as the assembly remains a functional sub-assembly devoid of independent utility outside the vehicle environment. Condition (c) is likewise met because the assembly is a specialized automotive part rather than a general-purpose flat panel display (CTH 8524) or a radio-broadcasting reception apparatus (CTH 8527), leaving the residual entry 8708 99 00 as the correct legal classification. In M/s Mitsubishi Electric Automotive India Pvt. Ltd. vs. Commissioner of Customs [Final Order No. 58663-58722/2024], the Tribunal observed: "Merely because it is in the form of a PCB and other electronic components does not change it from a part of an automobile into an instrument or an apparatus." 5.21 The ruling in M/s Continental Automotive Brake Systems India Private Limited v. Commissioner of Customs, Delhi /2024 (389) E.L.T. 93 (Tri-Del.)/, serves as binding precedent for the present matter, particularly given that the applic....