JUSTICE PRATHIBA M. SINGH JUSTICE SHAIL JAIN Prathiba M. Singh, J. (Oral)

1. This hearing has been done through hybrid mode.

2. The present appeal has been filed by the Appellant- Bharat Sanchar Nigam Limited (hereinafter, ‘B.S.N.L.’) under Section 130 of the Customs Act, 1962, assailing the order passed by the Customs, Excise & Service Tax AppellateTribunal, (hereinafter,‘CESTAT’),dated28^thJuly,2025,inAppeal Diary No. 55848 of 2024 (hereinafter, ‘impugned order’).

3. A brief background of the Appellant’s case is that, B.S.N.L., which is a telecommunications service provider, provides mobile voice and internet services through an expansive network across India. Certain tender was floated by the B.S.N.L., and Advance Purchase Orders (hereinafter, ‘APOs’) were released to the successful vendors. Certain equipment such as Baseband Unit Module (hereinafter, ‘BBU’) and Radio Access Technology (hereinafter, ‘RAT’) were to be imported and B.S.N.L. classified the same under particular classification being Customs Tariff Head 85176290.

4. However, due to a clarification which was issued by the Customs Department pursuant thereto, the classification was to be under Customs Tariff Head 85177090.