2025 (2) TMI 430 - AT - Customs

Classification of imported Multimedia Speakers and spare parts - classificable under heading no.85182200 or under heading no. 85279100? - HELD THAT - This issue was before the Banglore Tribunal in the case of Logic India Trading Co-v-C.C 2016 (3) TMI 5 - CESTAT BANGALORE . The Tribunal has held that the speakers should be classified under CTH 8518 22 00. Conclusion - The goods should be classified under heading no.85182200 as speakers rather than under heading no.85279100 as broadcast receivers. Appeal allowed.

Summary

The Appellate Tribunal considered the case of Jupiter International Ltd, which imported Multimedia Speakers and spare parts, classified under heading no.85182200 in their self-assessment. The dock officers later reclassified the speakers under heading no.85279100 as broadcast receivers, leading to a dispute. The appellant appealed against the reclassification, citing case law precedent and arguing for the original classification. The Revenue justified the reclassification under CTH 85279100. The Tribunal analyzed the issue based on precedent cases and relevant legal provisions.The Tribunal referred to the case of Logic India Trading Co-v-C.C-2016(337) ELT 65(Tri-Bang), where it was held that the main function of an item determines its classification. The Tribunal emphasized that the essential function of the goods in question was that of speakers, despite additional features like Bluetooth and FM radio. The Tribunal also cited the decision in Xerox India Ltd. v. Commissioner of Customs, Mumbai, to support the principle that the main function of a product determines its classification.In the case of B.C. (Port), Kolkata -v- M/s Santosh Radio Products, a similar issue was addressed, and it was held that goods described as "multi-media speaker system" should be classified as multimedia speakers under heading 8518, even with additional features like USB/FM. The Tribunal upheld this classification, emphasizing the essential function of the imported goods as multimedia speakers.Based on these precedents, the Tribunal ruled in favor of the appellant, setting aside the reclassification under CTH 85279100 and allowing the appeal. The Tribunal concluded that the product 'multimedia speakers' with additional functions such as FM Radio and USB port should be classified as speakers under Tariff Item 8518 22 00 of the Customs Tariff Act, 1975. The Tribunal's decision was consistent with previous rulings and legal principles regarding the classification of goods based on their main and essential function.In summary, the Tribunal considered the classification of Multimedia Speakers with additional functions, relying on case law precedents and legal principles to determine that the goods should be classified under heading no.85182200 as speakers, rather than under heading no.85279100 as broadcast receivers. The Tribunal's decision was based on the main function of the goods and upheld the appellant's classification, granting them the consequential relief as per law.