CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL, MUMBAI REGIONAL BENCH - COURT NO. 1 Customs Appeal No. 89472 of 2018 [Arising out of Order-in-Appeal No. MUM-CUSTM-AMP-APP-955/17-18 dated 19.01.2018 passed by the Commissioner of Customs (Appeals), Mumbai Zone-III, Mumbai.]

Flipkart India Private Limited .… Appellants Embassy Tech Village Campus Deverabeesinahallim Bellandur Bengaluru – 560 103.

Versus Commissioner of Customs (Import) …. Respondent Mumbai Air Cargo Complex, Sahar Andheri (East), Mumbai – 400 099.

APPEARANCE:

Shri Kishore Kunal, Advocate for the Appellant Shri Deepak Sharma, Authorized Representative for the Respondent CORAM:

HON’BLE S.K. MOHANTY, MEMBER (JUDICIAL)

HON’BLE MR. M.M. PARTHIBAN, MEMBER (TECHNICAL)

FINAL ORDER NO. A/85398/2026 Date of Hearing: 07.11.2025 Date of Decision: 09.03.2026 Per: M.M. PARTHIBAN This appeal has been filed by M/s Flipkart India Private Limited, Bengaluru (herein after referred to, for short, as “the appellants”) assailing the Order-in-Appeal No. MUM-CUSTM-AMP-APP-955/17-18 dated 19.01.2018 (hereinafter referred to, for short, as “the impugned order”) passed by the Commissioner of Customs (Appeals), Mumbai Zone-III, Mumbai.

2.1 The issue i