Case Details: Aisin Automotive Haryana Pvt. Ltd. vs. Commissioner of Customs, Delhi (2025) 34 Centax 250 (Tri.-Del)
Judiciary and Counsel Details
- Dr Rachna Gupta, Member (J) & Ms Hemambika R. Priya, Member (T)
- S/Shri Rajat Mittal, Onkar Sharma & Suprateek Neogi, Advs. for the Appellant
- Shri Nagendra Yadav, Authorized Representative, for the Respondent
Facts of the Case
The appellant, engaged in import of motor vehicle parts, imported goods described as ‘Cap-Sub-Assy Fr Door Outside Handle’ and claimed a different tariff classification to avail exemption. The Department contended that the goods were solely and principally designed for motor vehicles, had no independent usage, and were essentially door handles in an incomplete form. Reliance was placed on Section Note 3 of Section XVII, HSN Explanatory Note B of Heading 87.08, Rule 3(a) of the General Rules of Interpretation (GIR), and Rule 2(a) of GIR, to argue that such sub-assemblies had the essential character of finished door handles. The issue raised was whether the imported sub-assembly could be classified as a finished door handle under Customs Tariff Item 8708 29 00 of the Customs Tariff Act, 1975. The matter was accordingly placed before the Customs, Excise and Service Tax Appellate Tribunal (CESTAT).
CESTAT Held
The CESTAT held that the imported goods, being sub-assemblies exclusively designed for motor vehicle doors, were in the nature of finished door handles and thus classifiable under Customs Tariff Item 8708 29 00. The Tribunal reasoned that as per Rule 2(a) of GIR, an incomplete or unfinished article which has the essential character of the finished article is to be treated as complete, and in the present case, the addition of plastic material to affix the handle did not alter its essential function. Applying Rule 3(a) of GIR, the Tribunal concluded that the specific description of ‘finished door handle’ prevailed. The Tribunal further upheld the demand for interest on the ground that differential duty was payable consequent upon proper classification.
List Of Cases Cited
- B.E. Office Automation Products v. Commissioner — 2000 (122) E.L.T. 908 (Tribunal) — Referred [Para 3.2]
- Bhavnagar University v. Palitana Sugar Mills Pvt. Ltd. — AIR 2003 SC 511 — Referred [Para 3.5]
- Cast Metal Industries Pvt. Ltd. v. Commissioner — 2015 (325) E.L.T. 471 (S.C.) — Relied on [Para 15]
- Commissioner v. Bill Forge (P) Ltd. — 2012 (279) E.L.T. 209 (Kar.) — Referred [Para 3.7]
- Commissioner v. Jayathi Krishna and Co. — 2000 (119) E.L.T. 4 (S.C.) — Referred [Para 3.7]
- Commissioner v. Pearl Insulation Ltd. — 2012 (281) E.L.T. 192 (Kar.) — Referred [Para 3.7]
- Commissioner v. Qualcomm India Pvt. Ltd. — 2011 (22) S.T.R. 437 (Tribunal) — Referred [Para 3.1]
- Commissioner v. San Transmissions — 1999 (107) E.L.T. 482 (Tribunal) — Referred [Para 3.3]
- Commissioner v. Sony India Ltd. — 2008 (231) E.L.T. 385 (S.C.) — Referred [Para 3.2]
- Commissioner v. Uni Products India Ltd. — 2020 (372) E.L.T. 465 (S.C.) — Relied on [Paras 3.3, 10]
- HSBC Electronic Data Processing (India) Pvt. Ltd. v. Commissioner — 2014 (34) S.T.R. 577 (Tribunal) — Referred [Para 3.1]
- ITC Limited v. Commissioner — 2019 (368) E.L.T. 216 (S.C.) — Inapplicable [Paras 3, 7]
- L.G. Electronics India Pvt. Ltd. v. Commissioner — 2006 (204) E.L.T. 450 (Tribunal) — Referred [Para 3.2]
- National Steel Industries Ltd. v. Union of India — 2002 (139) E.L.T. 529 (M.P.) — Referred [Para 3.7]
- PDS Logistics International Pvt. Ltd. v. Commissioner — 2006 (4) S.T.R. 538 (Tri. – Bang.) — Referred [Para 3.1]
- Pratibha Processors v. Union of India — 1996 (88) E.L.T. 12 (S.C.) — Relied on [Paras 3.7, 16]
- S.K. Timber & Company v. Commissioner — 2021 (377) E.L.T. 454 (Tribunal) — Referred [Para 3]
- Sony India Ltd. v. Commissioner — 2002 (143) E.L.T. 411 (Tribunal-LB) — Referred [Para 3.2]
- Space Age Engg. Projects (P) Ltd. v. Collector — 1995 (78) E.L.T. 544 (Tribunal) — Referred [Para 3.2]
- Texla Enterprises v. Commissioner — 2002 (145) E.L.T. 537 (Tribunal) — Referred [Para 3.2]
- Thermax Ltd. v. Commissioner of Central Excise, Pune-1 — 2022 (382) E.L.T. 442 (S.C.) — Relied on [Para 9]
- Westinghouse Saxby Farmer Ltd. v. Commissioner — 2021 (376) E.L.T. 14 (S.C.) — Relied on [Para 14
