Case Details: Commissioner of Customs (Import), Mumbai Versus Bombay Fluid Systems Components Pvt. Ltd.- (2025) 27 Centax 33 (S.C.)
Judiciary and Counsel Details
- Sanjiv Khanna, CJ. & Sanjay Kumar, J.
- S/Shri Raghavendra P. Shankar, A.S.G., Karan Lahiri, Bhuvan Kapoor, Ms Vimla Sinha, Advs. & Gurmeet Singh Makker, AOR, for the Appellant.
- S/Shri V. Lakshmikumaran, Ms Neha Choudhary, Ms Umang Motiyani, Ayush Agarwal, Ms Falguni Gupta, Advs. & Ms Charanya Lakshmikumaran, AOR, for the Respondent.
Facts of the Case
The assessee, an importer, classified stainless steel tube fittings (‘Tees and Crosses’) under Tariff Item 7307 22 00 (‘Threaded elbows, bends, and sleeves’) of the Customs Tariff Act, 1975. However, customs authorities, including the Commissioner (Appeals), rejected this classification, determining that the goods fell under the residual category of Tariff Item 7307 29 00 (‘Other’ fittings). The importer appealed to the Customs, Excise, and Service Tax Appellate Tribunal (CESTAT), which examined pictorial evidence and trade usage, concluding that the goods functioned as bends or elbows. CESTAT ruled in favor of classification under Tariff Item 7307 22 00, also noting inconsistencies in departmental classification, as identical goods imported by others had been classified under the same tariff without objection. Dissatisfied with this decision, the Revenue approached the Supreme Court.
Supreme Court Held
The Hon’ble Supreme Court upheld CESTAT’s ruling, affirming that ‘Tees and Crosses’ fell under Tariff Item 7307 22 00 as ‘Threaded elbows, bends, and sleeves.’ The Court emphasized that a specific classification takes precedence over a general one. Since the goods functioned as bends or elbows per trade understanding, they could not be categorized under the residual Tariff Item 7307 29 00 (‘Other’). Dismissing the Revenue’s appeal, the Court reinforced the importance of consistency and specificity in customs classification, ensuring legal certainty for importers.
List of Cases Reviewed
- Bombay Fluid Systems Components Pvt. Ltd. v. Commissioner — (2024) 23 Centax 133 (Tri. – Mumbai) — Affirmed
