Case Details: Principal Commissioner of Customs, ACC Import, New Delhi Versus Samsung India Electronics Pvt. Ltd. (2025) 32 Centax 463 (S.C.)
Judiciary and Counsel Details
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B.V. Nagarathna and Dipankar Datta, JJ.
- S/Shri Rupesh Kumar, Sr. Adv. N. Venkatraman, A.S.G., V.C. Bharti, Ms. Priyanka Das, Chitvan Singhal, Udai Khanna, Prakash Chand Agarwal, Advs. and Gurmeet Singh Makker, AOR, for the Petitioner.
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S/Shri V. Lakshmikumaran, Sr. Adv., Ms. Apeksha Mehta, Ms. Neha Choudhary, Ms. Falguni Gupta, Ms. Umang Motiyani, Ms. Aayush Agarwal, Advs. and Ms. Charanya Lakshmikumaran, AOR, for the Respondent.
Facts of the Case
The Respondent-assessee imported front, middle, and back covers made of plastic, which were exclusively used as parts of mobile phones. The Customs authorities classified these goods under Heading 3920 of the Customs Tariff, treating them as parts of general use made of plastic. The Respondent-assessee contended that the goods were specifically meant for mobile phones and were appropriately classifiable under Tariff Item 8517 70 90. The CESTAT held that, applying the Rules of Interpretation, the specific entry for parts of mobile phones prevailed over the general entry for articles of plastic, and the later entry in Chapter 85 prevailed over the earlier entry in Chapter 39. It concluded that the mobile covers were specific parts for mobiles and were appropriately classifiable under Tariff Item 8517 70 90 instead of goods of Chapter 39. The Department of Revenue filed an appeal before the Supreme Court.
High Court Held
The Hon’ble Supreme Court held that, following its earlier order in the case reported as [(2025) 32 Centax 241 (S.C.)], the impugned order of the CESTAT was to be upheld. It confirmed that the mobile covers in question were specific parts for mobiles and were appropriately classifiable under Tariff Item 8517 70 90, and not under Heading 3920 meant for parts of general use. The Court further affirmed the CESTAT’s finding that the specific entry prevailed over the general entry, and the later entry prevailed over the earlier entry, in terms of the General Rules for the Interpretation of the Customs Tariff. The appeal filed by the Revenue was accordingly dismissed.
List Of Case Reviewed
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Samsung India Electronics Pvt. Ltd. v. Principal Commissioner — (2024) 20 Centax 343 (Tri. – Del.)
List Of Case Cited
- Principal Commissioner v. Padget Electronics Pvt. Ltd. — (2025) 32 Centax 241 (S.C.)
