2026-VIL-685-CESTAT-DEL-CU

CUSTOMS CESTAT Cases

Customs – Classification, parts and accessories of motor vehicles - The appellant imported track assembly, brake/case sub assembly, gear vertical adjuster, and bar seat track lock - Whether the goods imported by the appellant deserve to be classified under CTI 9401 90 00 as ‘parts of seats’ as claimed by the appellant or they deserve classification under CTI 8708 99 00 as ‘parts and accessories of motor vehicles’ as claimed by the department – HELD - The goods imported by the appellant, including track assembly, gear vertical adjuster, case sub-assembly seat vertical, brake sub-assembly vertical and bar seat track lock, are parts of seats and classifiable under CTI 9401 90 00. The Commissioner acted in breach of judicial discipline by not following the binding precedent of the Tribunal, which had held that similar child parts imported by the appellant were classifiable under CTI 9401 90 00 as parts of seats - The Commissioner's reliance on Advance Rulings and the Supreme Court decision in Insulation Electrical is misplaced, as the Tribunal had distinguished those cases - It is not in dispute that the appellant had been selling the imported parts directly to the car seat manufacturers and not to the car manufacturers. The ‘track assembly’ is an integral part of a complete seat and is supplied to a car seat manufacturer for manufacture of the seats. ‘Gear vertical adjuster’ is affixed in a car seat at a particular location along with brake seat lifter. ‘Track assembly’ helps in the upward and downward seat adjustment. ‘Bar seat track lock’ is used to lock the position of the seat at the required position. Therefore, it cannot be doubted that all the four parts imported by the appellant are parts of car seats and cannot be described as ‘parts’ and ‘accessories’ of motor vehicles. The appellant, therefore, correctly classified the goods under CTI 9401 90 00 as ‘parts of seats’ - The impugned order is set aside and the appeal of the appellant is allowed

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