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Supreme Court of India 2023-03-29 dismissed

CCE, AURANGABAD vs M/S VIDEOCON INDUSTRIES LTD

Bench: 2 — S. Ravindra Bhat, Dipankar Datta

In Brief

Two revenue appeals challenged orders classifying imported LCD panels under Chapter Heading 9013.8010 (Liquid Crystal Devices) rather than under chapters covering television sets and car audio systems. The Supreme Court dismissed both appeals, holding that LCD panels are specifically and correctly classified under Chapter 9013.8010. The Court emphasized that the most specific tariff heading must be preferred over general ones; that Chapter Note 1(m) to Chapter 85 excludes Chapter 90 goods entirely; and that the test of "principal use" applies only to determine if goods are parts and accessories, not to override specific headings that describe the goods themselves. The commercial identity or intended use of LCD panels does not change their tariff classification as distinct articles.

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Customs Law Tariff Classification Import Duties Excise Law

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