Car Seat Track Assembly Classifiable as Seat Part

Centax Editorial Board

April 15, 2026April 16, 2026

• 4 min. read

Case Details: Daebu Automotive Seat India (P.) ltd. vs. Commissioner of Customs (Audit), Chennai (2026) 41 Centax 77 (Tri.-Mad)

Judiciary and Counsel Details

S/Shri P. Dinesha, Member (J) & M. Ajit Kumar, Member (T)
Shri Hari Radhakrishnan, Adv. for the Appellant.
Shri P. Narasimha Rao for the Respondent.

Facts of the Case

The appellant, an importer, had classified the imported track assembly used in car seats under heading 9401 as parts of seats, treating the same as components essential to the seat assembly. The department, pursuant to investigation by the Directorate of Revenue Intelligence, took the view that the impugned goods were not parts of seats but were in the nature of base mounting components affixed to the floor of motor vehicles. Accordingly, the adjudicating authority rejected the classification declared by the appellant under heading 9401 and reclassified the goods under heading 8708 as motor vehicle parts. The appellant challenged the said reclassification, contending that the track assembly is an integral component of car seats and is classifiable as seat parts based on functional use and trade understanding. The matter was accordingly placed before the Customs, Excise and Service Tax Appellate Tribunal (CESTAT).

CESTAT Held

The CESTAT held that the classification of the impugned track assembly is required to be determined based on its functional utility as an integral and dedicated component of car seats. It was observed that the goods are specifically designed for seat mechanisms and cannot be treated as independent motor vehicle accessories falling under heading 8708. The Tribunal further held that the department had failed to discharge the burden of establishing that the classification declared under heading 9401 was incorrect. Accordingly, it was concluded that the appropriate classification of the impugned goods is under heading 9401 as parts of seats, and the reclassification under heading 8708 was not sustainable.

List of Cases Cited

Anandji Haridas & Co. Pvt. Ltd. v. Engineering Mazdoor Sangh — (1975) 3 SCC 862 — Relied on [Para 19.8]
Annapurna Carbon Industries Co. V. State of Andhra Pradesh — (1976) 2 SCC 273 — Referred [Para 8.2]
Assistant Director of Income Tax v. Green Emirate Shipping and Travels — (2006) 100 ITD 203 (Mum) — Noted [Para 13.1]
Bharat Forge Ltd. v. Commissioner — 2012 (284) E.L.T. 280 (Tribunal) — Noted [Para 12.1]
Bharat Sanchar Nigam Ltd. v. Union of India — 2006 (2) S.T.R. 161 (S.C.) — Noted [Para 12.5]
Bhavnagar University v. Palitana Sugar Mills Pvt. Ltd. — (2003) 2 SCC 111 — Referred [Para 17.2]
Birla Corporation Ltd. v. Commissioner — 2005 (186) E.L.T. 266 (S.C.) — Noted [Para 12.5]
Boving Fouress Ltd. v. Commissioner — 2006 (202) E.L.T. 389 (S.C.) — Noted [Para 12.5]
Bush Boake Allen (India) Ltd. v. Union of India — 1995 (77) E.L.T. 529 (Mad.) — Noted [Para 12.4]
Chemplast Sanmar Ltd. v. Commissioner — 2018 (364) E.L.T. 345 (Tribunal) — Distinguished [Para 18]
Chief Commissioner v. Safari Retreats Pvt. Ltd. — 2024 (90) G.S.T.L. 3 (S.C.) = (2024) 23 Centax 62 (S.C.) — Relied on [Para 19.7]
Commissioner v. Bosch Ltd. — (2024) 21 Centax 27 (Tri.-Bang) — Distinguished [Para 18]
Commissioner v. C-Net Communication (I)Pvt. Ltd. — 2007 (216) E.L.T. 337 (S.C.) — Referred [Para 8]
Commissioner v. Insulation Electrical Pvt. Ltd. — 2008 (224) E.L.T. 512 (S.C.) — Distinguished [Paras 3.1, 3.2, 12.2, 17, 17.1, 17.2, 17.3, 18.1]
Commissioner v. Pepsico India Holdings Ltd. — 2001 (130) E.L.T. 193 (Tribunal) — Noted [Para 12.5]
Commissioner v. Shiroki Auto Components India Pvt. Ltd. — 2021 (378) E.L.T. A145 (S.C.) — Referred [Para 13.2]
Cross Ruling No. N042783, dated 20-11-2008 by US Ruling — Referred [Para 16]
Cross Ruling No. N105216, dated 26-5-2010 by US Ruling — Referred [Para 16]
Cross Ruling No. NY R04583, dated 14-8-2006 by US Ruling — Referred [Para 16]
Cross Ruling No. NY R04586; HQ965970, dated 14-10-2003 by US Ruling— Referred [Para 16]
Cross Ruling No. Y J89545, dated 16-10-2003 by US Ruling — Referred [Para 16]
Daebu Automotive Seat India Pvt. Ltd. — Order No. 17/AAR/2021, dated 7-5-2021 by Authority for Advance Ruling, Tamil Nadu— Referred [Para 13]
Deputy Commissioner v. Union Carbide India Ltd. — (1976) 38 STC 198 (Ker) — Referred [Para 8.1]
Dunlop India Ltd. v. Union of India — 1983 (13) E.L.T. 1566 (S.C.) — Distinguished [Para 12.1]
Guru Overseas Pvt. Ltd. v. Collector — 2000 (120) E.L.T. 209 (Tribunal) — Distinguished [Para 18]
Hewlett Packard India Sales Pvt. Ltd. v. Commissioner — 2023 (383) E.L.T. 241 (S.C.) = (2023) 2 Centax 236 (S.C.) — Noted [Para 5.1]
Hyundai Motors India Ltd. v. Commissioner — (2025) 34 Centax 231 (Tri.-Mad) — Relied on [Para 14.1]
Indian Oil Corporation Ltd. v. Collector — 2006 (202) E.L.T. 37 (S.C.) — Noted [Para 12.5]
Lloyd Electric and Engineering Ltd. v. State of Himachal Pradesh — 2015 (324) E.L.T. 248 (S.C.) — Noted [Para 12.5]
Commissioner v. KSS Abhishek Safety Systems Pvt. Ltd. — Final Order No. 55493/2024, dated 8-4-2024 by CESTAT, New Delhi — Relied on [Para 19.9]
Pragati Silicons Pvt. Ltd. v. Commissioner — 2007 (211) E.L.T. 534 (S.C.) — Referred [Para 8.3]
Senairam Doongarmall v. Commissioner of Income Tax — 2002-TIOL-1053-SC-IT-LB — Referred [Para 17.2]
Shiroki Auto Components India Pvt. Ltd. v. Commissioner — 2020 (374) E.L.T. 433 (Tribunal) — Referred [Para 13.2]
Shiroki Technico India Pvt. Ltd. — Advance Ruling No. GUJ/GAAR/R/42/2020, dated 30-7-2020 by Authority for Advance Ruling, Gujarat — Noted [Para 13.2]
State of U.P. v. Sukhpa Singh Bal — AIR 2005 SC 3324 — Relied on [Para 19.6]
Sterlite Industries (India)Ltd. v. Commissioner — 2007 (210) E.L.T. 180 (S.C.) — Noted [Para 5.1]
Superintendent & Legal Remembrancer, State of West Bengal v. Corporation of Calcutta — (1967) 2 SCR 170 — Relied on [Para 19.7]
Supreme Motors v. State of Karnataka — 1987 (27) E.L.T. 409 (Kar.) — Referred [Para 8.4]
Swastik Creation v. Commissioner — Final Order Nos. A/86089-86090/2022, dated 18-11-2022 by CESTAT, Mumbai — Relied on [Para 19.9]
Union of India v. Azadi Bachao Andolan — AIR 2004 SC 1107 — Noted [Para 13.1]
Union of India v. Garware Nylons Ltd. — 1996 (87) E.L.T. 12 (S.C.) — Referred [Para 9.1]
York Barbell Company Ltd. v. Canada — (DMNRCE), AP-90-161, [1991] CITT No 43 — Relied on [Paras 8, 11]