2026-VIL-02-SC-CU
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CUSTOMS Supreme Court Cases

Customs - Classification aluminium shelves imported along with other equipment, for mushroom cultivation - Revenue authorities sought to classify the aluminium shelves under CTI 76109010 as 'Aluminium Structures', while the respondent claimed classification under CTI 84369900 as 'Parts of Agricultural Machinery' - Whether the aluminium shelves can be classified as 'Aluminium Structures' under CTI 76109010 or as 'Parts of Agricultural Machinery' under CTI 84369900 – HELD - Chapter Heading 7610 is purely an eo-nomine provision and makes no reference to use in any manner whatsoever, either explicitly or inherently. An eo-nomine provision is one that describes a commodity by its name. A use limitation cannot be imposed on an eo-nomine provision unless the name inherently suggests use. An eo-nomine provision would ordinarily include all forms of the name article. Consequently, Chapter Heading 7610 would cover all forms of aluminium structures, except for prefabricated buildings of heading 94.06, which have been excluded by the heading itself - On the basis of examining the objective characteristics and properties of the subject goods, it is evident that the subject goods fulfil the characteristics and unquestionably fall within the category of structures. Even in common parlance, the subject goods would be referred to as structures. Therefore, the subject goods are classifiable under CTI 76109010 as Aluminium Structures – Further, the subject goods also fail to qualify as parts of the machines with which they are integrated post-importation. All of the individual machines are already complete and fully operational on their own, i.e., their mechanical and electrical functions do not rely on the aluminium shelves. These shelves do not contribute to their operation; they merely serve as a surface for the devices to perform their functions. Looked at from any angle, the subject goods cannot be classified under Chapter Heading 8436. Consequently, the subject goods are liable to be classified under CTI 76109010 as ‘Aluminium Structures’ – The impugned order passed by the Tribunal is set aside and the Revenue appeal is allowed
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