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Supreme Court of India 2020-05-01 dismissed

COMMISSIONER OF CENTRAL EXCISE, DELHI-III vs M/S. UNI PRODUCTS INDIA LTD

Bench: 2 — Deepak Gupta, Aniruddha Bose

In Brief

The Supreme Court held that car mattings manufactured by the respondent should be classified under Chapter 57 (Carpets and Other Textile Floor Coverings), heading 5703.90 of the Central Excise Tariff Act, 1985, not under Chapter 87 (Parts and Accessories of Motor Vehicles). Though made specifically for use in vehicles, the HSN Explanatory Notes explicitly exclude textile carpets from classification as vehicle accessories and place them under Chapter 57. The Court rejected the revenue's argument that exclusive use in motor vehicles warranted classification as parts, reasoning that the tariff entry must reflect the goods' essential nature (textile floor covering) rather than their specific end-use. The Tribunal's decision in favour of the assessee was upheld and the revenue's appeals were dismissed.

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Tariff Classification Excise Duty Goods Classification Trade and Commerce

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