CUSTOMS, EXCISE & SERVICE TAX APPELLATE TRIBUNAL, MUMBAI REGIONAL BENCH - COURT NO. 2 Customs Appeal No. 87078 of 2025 (Arising out of Order-in-Appeal No. MUM-CUSTM-AMP-APP-171/2025-26 dated 07.05.2025 passed by the Commissioner of Customs (Appeals), Mumbai Zone – III)

M/s Wipro GE Healthcare Pvt. Ltd. .… Appellant C/s DHL Supply Chain India Pvt. Ltd.

BGR Warehousing Complex, Building No. 3, Vahuli, Mumbai Nashik Highway, Bhiwandi, Thane – 421 302 Versus Commissioner of Customs (Import), Mumbai-III …. Respondent Air Cargo Complex, Sahar, Andheri (East), Mumbai – 400 099 WITH Customs Appeal No. 87079 of 2025 (Arising out of Order-in-Appeal No. MUM-CUSTM-AMP-APP-170/2025-26 dated 07.05.2025 passed by the Commissioner of Customs (Appeals), Mumbai Zone – III)

M/s Wipro GE Healthcare Pvt. Ltd. .… Appellant C/s DHL Supply Chain India Pvt. Ltd.

BGR Warehousing Complex, Building No. 3, Vahuli, Mumbai Nashik Highway, Bhiwandi, Thane – 421 302 Versus Commissioner of Customs (Import), Mumbai-III …. Respondent Air Cargo Complex, Sahar, Andheri (East), Mumbai – 400 099 APPEARANCE:

Shri Roshil Deepak Nichani, Advocate for the Appellant Shri Jitesh Kumar Jain, Authorized Representative for the Respondent CORAM:

HON’BLE DR. SUVENDU KUMAR PATI, MEMBER (JUDICIAL)

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

FINAL ORDER NO. A/85319-85320/2026 Date of Hearing: 17.12.2025 Date of Decision: 19.02.2026 PER: M.M. PARTHIBAN These appeals have been filed by M/s Wipro GE Healthcare Private Limited, Thane (herein after, referred to as ‘the appellants’) assailing two Orders-in-Appeal being No. MUM-CUSTM-AMP-APP-170/2025-26 and No. MUM-CUSTM-AMP-APP-171/2025-26, both dated 07.05.2025, (herein after referred to as ‘the impugned orders’) passed by the same first appellate authority viz., Commissioner of Customs (Appeals), Mumbai Zone – III.

2.1 The facts of the case, leading to these appeals, are summarized herein below:

2.2 The appellants herein, had imported "LCD HB Colour Monitors without Stand, of size 19 inch" for use with medical equipment such as ultrasound machines, X-Ray machines, CT Scan and Magnetic Resonance Imaging system etc., through Air Cargo Complex (ACC), Mumbai and for this purpose, have filed various Bills of Entry (B/Es) periodically during the disputed period from December 2018 to February 2021, by classifying the "LCD HB Colour Monitors" under Customs Tariff Heading (CTH) 8528. The appellants have self-assessed the customs duty payable thereon by claiming the effective rate of Integrated Goods and Services Tax (IGST) payable @ 18%, as applicable to ‘computer monitor’ under Serial Nos. 383C & 384 of Schedule-

III to Notification No. 01/2017-Integrated Tax (Rate) dated 28.06.2017.

2.3 During the post clearance audit of the import transactions of the appellants, the department had objected to the classification/categorization of imported monitors adopted by the appellants for payment of IGST at the rate of 18%, under Serial Nos. 383C & 384 of Schedule-III, as against the claim of the department that applicable rate is of 28%, under entry in serial No. 154 of Schedule-IV, of the notification dated 28.06.2017, on the ground that the impugned goods are ‘other’ monitors which are designed to be used with medical equipment, X-Ray machines and are not for use with the computers or Automatic Data Processing machine (ADP). Accordingly, the department had proposed for revising the classification / categorization of imported goods to fall under IGST rate @ 28% in terms of entry at serial No. 154 of the Schedule-IV of Notification No.01/2017-IT(Rate) dated 28.06.2017. On the above understanding, the department had initiated show cause proceedings including holding of pre-notice consultation with the appellants. On completion of such process, the department had issued of Show Cause Notices (SCNs) dated 15.06.2023 and 19.12.2023, for revising the classification/ categorization and demanding differential duty of customs in respect of the subject B/Es during the