Imported goods must be classified based on their specific tariff heading rather than their ultimate end-use. Under the Customs Tariff, specific entries for articles take precedence over general 'parts and accessories' entries, and the condition of goods at the time of import is the sole factor for classification.

DATE OF HEARING : 13.02.2026

DATE OF DECISION :26.05.2026

Per: Shri P. Dinesha

This Appeal is filed by M/s.Johnsons Control Private Ltd., the Appellant herein, against Order-in-Original No.265/2016 dated 30.03.2016 passed by the Principal Commissioner of Customs, Chennai-VII. The issue involves the classification of ‘LCD panels’ imported by the Appellant and the relevant and necessary facts as could be gathered from the documents placed on record and upon hearing both the parties are as under:

2. The Appellant admittedly had imported LCD panels to be used in the manufacture of Automotive Instrument Clusters (AIC) by classifying the same in the relevant Bills of Entry under CTH 9013 which attracted NIL rate of duty. The Revenue taking a cue from the intelligence and the investigation conducted by the Delhi Zonal Unit of DRI, was of the view that the subject goods that is ‘LCD panels’ which are essentially the integral parts of AIC, are required to be classified under CTH 87089900 / 87149010 as parts of motor cars/motor cycles/commonly referred to as ‘motor vehicles’ and hence, the Appellant–Importer had deliberately misdeclared the subject goods as ‘Liquid Crystal Display’ instead of describing it as ‘essential and integral parts of clusters’ and thereby evaded Customs duty. Based on the alleged evidence gathered during investigation, it appears that a SCN dated 12.05.2014 was issued on the grounds that the LCD panels were customized/designed as per the specifications and requirements of vehicle manufacturers and, therefore, cannot be used for any application other than in the manufacture of Cluster/AIC for motor vehicles and model numbers for which they are designed; CTH 9013 covers ‘Liquid Crystal Devices’ not constituting articles provided for more specifically in other Headings, thereby indicating that the above Heading is in the nature of a residual entry i.e the classification under this Heading is ruled out if the goods are more specifically covered in any other Heading or Entry; by application of Section Note 3 to Section XVII of the CTA, the subject goods being designed and suitable only for use solely with AIC, merits classification under CTH 8708 / 8714 as ‘parts and accessories for motor vehicles’ as this Headings are more specific; classification of Clusters i.e AIC under Chapter Heading 8708 as ‘parts and accessories of motor vehicles’ has also been clarified by CBEC vide Circular No.341/57/97–CX dated 07.10.1997 and even the Delhi Bench of the Tribunal in the case of CCE, Delhi Vs Premier Instruments and Controls Ltd. [2000 (123) ELT 657 (Tri.) followed in 2004 (174) ELT 49 (Tri.-Chennai)] has also settled the issue of classification; with the introduction of self-assessment scheme from 08.04.2011, it is the responsibility of the Importer to declare the correct description to correctly classify and pay the duty; in the Bills of Entry filed at the time of import, the Appellant did not give complete description of the goods, which only read as ‘Liquid Crystal Device’ and in some cases, numbers were added, but without indicating the intended purpose/usage of the subject goods; the classification of subject goods is dependent on the sole use as the LCD panels being imported, the correct classification could not have been determined based on generic description without there being any hint or divulgence as to the usage of the goods in question; other importers have been importing si