Case Details: Samsung India Electronics Pvt. Ltd. vs. Commissioner of Customs, Chennai (2025) 34 Centax 174 (Tri.-Mad)
Judiciary and Counsel Details
- Ms Sulekha Beevi C.S., Member (J) & Vasa Seshagiri Rao, Member (T)
- Shri V. Lakshmikumaran, Adv., for the Appellant
- Shri Harendra Singh Pal, Assistant Commissioner (A.R.), for the Respondent
Facts of the Case
The appellant imported LED Monitor Tiles and claimed classification under Customs Tariff Item 8528 52 00, seeking benefit of exemption under Notification No. 24/2005-Cus., dated 01-03-2005. The goods were described as LED Monitor Tiles having necessary ports for connection to an ADP machine, including ports for Power In and Power Out, and capable of interconnection through LVDS (Low-Voltage Differential Signaling) cables. It was submitted that the subject goods cannot function independently and necessarily require connection either with Samsung Set Box (SBB) or similar device, which acts as a control PC. It was further explained that the signal input from the SBB to LED Monitor Tiles flows through LVDS cable, and alternatively, the Tiles can also be connected to a GDC server with inbuilt software and a 32TB memory, classifiable under Heading 8471 as an Automatic Data Processing Machine. On this basis, the appellant contended that LED Monitor Tiles are designed for use with ADP machines and therefore fall under Tariff Item 8528 52 00, making them eligible for exemption under the said Notification. The matter was accordingly placed before the Customs, Excise and Service Tax Appellate Tribunal (CESTAT).
CESTAT held
The CESTAT held that LED Monitor Tiles are capable of being connected to and used with an ADP machine, as they receive signals only through such devices and do not function independently. It was observed that the subject goods contain the necessary ports for such connectivity and are designed for operation either through SBB or GDC servers, thereby meeting the criteria for classification under Customs Tariff Item 8528 52 00. The Tribunal clarified that the functional dependence on ADP machines and the technical specifications supported this classification, rejecting any alternative tariff headings. Consequently, the benefit of Notification No. 24/2005-Cus., dated 01-03-2005 was held to be admissible to the appellant.
List of Cases Cited
- Acer India (P) Ltd. v. Commissioner — 2009 (11) TMI 931-CESTAT Ahmedabad — Referred [Paras 8.4, 36]
- Benq India Pvt. Ltd. v. ADG — 2022 (9) TMI 690-CESTAT New Delhi — Referred [Paras 8.4, 11.8, 36]
- Commissioner v. Aveco Viscomm Pvt. Ltd. — 2011 (263) E.L.T. 420 (Tribunal) — Referred [Para 8.4]
- Commissioner v. Dell India Pvt. Ltd. — 2008 (226) E.L.T. 367 (Tribunal) — Referred [Para 7.3]
- Commissioner v. Epson India Private Ltd. — 2019 (366) E.L.T.A173 (S.C.) — Referred [Para 8.4]
- Commissioner v. Vardhaman Technology Pvt. Ltd. — 2014 (301) E.L.T. 427 (Tribunal) — Referred [Para 8.4]
- Epson India Pvt. Ltd. v. Commissioner — 2019 (366) E.L.T. 847 (Tribunal) — Referred [Para 8.4]
- Godrej Sara Lee Ltd. v. Excise and Taxation Officer-Cum-Assessing Authority — 2023 (384) E.L.T. 8 (S.C.) = (2023) 3 Centax 49 (S.C.) — Referred [Para 49]
- IBM India Pvt. Ltd. v. Commissioner — 2009 (244) E.L.T. 383 (Tribunal) — Referred [Para 7.3]
- Pepsico Holdings Pvt. Ltd. v. Commissioner — 2019 (25) G.S.T.L. 271 (Tribunal) — Referred [Para 11.9]
- Sony India Pvt. Ltd. v. Commissioner — 2019 (370) E.L.T. 1774 (Tribunal) — Referred [Para 8.4]
- Warner Hindustan Ltd. v. Collector — 1999 (113) E.L.T. 24 (S.C.) — Referred [Paras 6.12, 11.9]
