2025-VIL-08-AAR-CU
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CUSTOMS Advance Ruling Authority

Customs AAR - Whether the various parts and components which are used in the manufacturing of mobile phones are eligible for concessional rate of Basic Customs Duty at 10% under Serial No. 6D (xi) and (xii) of Notification No. 57/2017-Cus., dated 30.06.2017, as amended by Notification No. 09/2024-Cus., dated 30.01.2024 – HELD – While the purpose of the notification is to benefit the mobile phone manufacturing industry, a purposive interpretation cannot override the specific language used by the legislature. The notification deliberately creates different categories for different types of goods (e.g., "mechanical items" under 6D, "films" under 6F). Interpreting "mechanical items" to subsume all other categories would render the specific entries redundant, violating the settled principle of statutory interpretation that every word in a statute must be given meaning – The items- Plastic and Metal Supports, Brackets, and Fixed Supports (e.g., Main Board Support, Antenna Support, Camera Module Support, Various Button Supports, BTB Support, USB Socket Fixed Support), Stoppers: (e.g., Card Column Stopper, Front Cover Stopper), SIM Card Tray Hole Pushrod, and Gasket /block/ baffle (metal) - SIM Card Tray Plectrum are eligible for the benefit of BCD at 10% under the relevant entries of Serial No. 6(D) of Notification No. 57/2017-Cus., as amended - The items- Diffusion Films, Photosensitive Diffusion Films, Waterproof Breathable Membranes, Protective Films, Light Pipes, Light Guides, Flash Lamp Cover, Steel Vapor Chamber, and Shielding Case (Metal) do not meet the criteria of "mechanical items" as intended by the notification and are therefore not eligible for the exemption under Sr. No. 6D (xi) or (xii) of Notification No. 57/2017-Cus., as amended – Ordered accordingly
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