2024(01)LCX0392(AAR)

Vivo Mobile India Private Limited

decided on 31-01-2024

CUSTOMS AUTHORITY FOR ADVANCE RULINGS
O/o THE CHIEF COMMISSIONER OF CUSTOMS
NEW CUSTOM HOUSE, NEAR IGI AIRPORT, NEW DELHI-110037
[Email: cus-advrulings.del@gov.in]
 

Present
Samar Nanda (Customs Authority for Advance Rulings, New Delhi)

F. No. VIII/CAAR/Delhi/Vivo Mobile India(P) Ltd./ 59/2023

The day of 31^st January, 2024
 

Ruling No. CAAR/Del/Vivo Mobile India/03/2024 / 675/ 01-02-2024

In Application no. 30/2023 dated 03.11.2023

Ruling

M/s. Vivo Mobile India Pvt. Ltd., 10th & 11th Floor, Palm Spring Plaza (Complex), Village-Wazirabad, Sector-54, Gurugram, Haryana having IEC No. 0514053739(‘applicants’, in short) have filed an application (CAAR-1) for advance ruling before the Customs Authority for Advance Rulings, New Delhi (CAAR, in short). The said application was received in the Secretariat of the CAAR, New Delhi on 03.11.2023 along with enclosures in terms of Section 28H(1) of the Customs Act, 1962 (hereinafter referred to as the Act’). The applicants are engaged in import of Main MIC Dust Protective Net and have sought ruling on classification thereof under the Customs Tariff Act, 1975 by posing a question, Whether Main MIC Dust Protective Net (subject goods, in short) can be classified under Tariff Item 59119090?

2.1 The applicants have stated that, in the usual course, they are importing various products and parts which are being used in the manufacturing of smartphones; in a similar way, they intend to import the subject goods for manufacturing of smartphone; Dust Protective Net is used in various models having separate product IDs however, the description and functionality of the subject goods remain the same irrespective of product code and the model in which it is used; the detailed description of the subject goods is as follows: It is a filtering/protective aid; the main body is made up of Mesh Fabric and back base is of anti-static blue protective film with single sided self-adhesive; the main body of Mesh Fabric as well as back base protective film are made of Poly Ethylene Terephthalate (“PET”), which is the most common thermoplastic polymer resin of the polyester family and is used in fibres for clothing; the subject goods are used for mobile phone speaker to prevent from dust; the sound resistance of the subject goods is small because net is clear and precise as well as the net is waterproof and oil-proof and it has a large air permeability; moreover, on account of the protective net most of the mixed sounds are filtered out, and thus the acoustic quality of speaker is improved, and the sound becomes clearer; the subject goods are applied to the speaker of the mobile phone with the help of one side self-adhesive to play the role of dustproof and waterproof protective net. In light of the above, the applicant has stated that they intend to import the goods in question under Sub-heading 59119090 of the Customs Tariff and mentioned that, presently, they are importing the Dust Protective Net under Sub­heading 39269099.

2.2 It is further stated that, Dust Protective Net is in the nature of a textile material, used for technical purposes; the goods in question, imported by them are of precise measurement and are made up of synthetic fibre which is covered within the meaning of woven fabric; the technical usage of the subject goods is filtering/protecting dust coupled with the fact that it is made of synthetic fibre which excludes it from the purview of Section XVI and consequently Chapter of 85 of the Customs Tariff Act; further, such products are also excluded from the scope of Chapter 39 as it is expressly provided in the Chapter Notes to Chapter 59 that such filtering textiles products which are made of woven fabrics, which includes PET, are covered under the CTH 5911; Dust Protective Net is made up of Mesh Fabric and a protective layer which is made up of textile fabric: the subject goods have small rectangular shape and are used in mobile phones for the purpose of filtering and providing protective aid to mobile phone speakers; since, the subject goods are made up of woven fabric of PET and has technical use of protective layering, the same is covered under Chapter 59 of Schedule 1 of the Customs Tariff Act and specifically classifiable under Sub-heading 59119090.

2.3 In support of the proposed classification of the subject goods, it is submitted by the applicants that, Note 1 to Chapter 59 provides that the term “textile fabrics” used in Chapter 59 applies to woven fabrics of Chapter 50 to 55 which includes PET MeshFabric of Chapter 54; in the instant case, the Dust Protective Net, made of PET mesh fabric, a woven fabric of Chapter 54 classified under Heading 5407 which covers woven fabrics of synthetic filament; will fall within the meaning of synthetic fibres as per Explanatory Note sand consequently, withing the meaning of Textile fabrics; further, in terms of Note 8 of Chapter 59, when such textile fabrics are used for technical use, they fall under CTH 5911 which is evident from Explanatory Notes to CTH 5407 which reads as follows: This heading covers woven fabrics (as described in Part (I) (C) of the General Explanatory Note to Section XI) made of synthetic filament yarn or of monofilament or strip of heading 54.04; it includes a very large variety of dress fabrics, linings, curtain materials, furnishing fabrics, tent fabrics, parachute fabrics, etc. This heading does not include: (a) Bandages medicated or put up for retail sale (heading 30.05). (b) Woven fabrics of synthetic monofilament of which any cross-sectional dimension exceeds 1 mm or of strip or the like of an apparent width exceeding 5 mm, of synthetic textile materials (heading 46.01). (c) Woven fabrics of synthetic staple fibres (headings 55.12 to 55.15). (d) Tyre cord fabric of heading 59.02. (e) Woven fabrics for technical uses, of heading 59.11; therefore, it is evident that woven fabrics which include fabric of synthetic filament yarn, when used for technical purposes, will be covered under CTH 5911.

2.4 The applicants have also stated that in this regard, the US Customs and Border Protection in its classification ruling, (US CROSS Ruling NY 180898 dated May 24, 2002), has held that the products having similar technical composition of polymer fabric covered under Chapter 54 and technical usage will be covered under Heading 5911; the relevant extracts of this ruling are: Correspondence and a phone conversation with a staff member of Texlon indicates that this woven material is used as a backing or support for a membrane polymer that is cast on to one surface of the fabric. Such a membrane, in this instance, could be polysulfide, a thermoplastic polymer that is further treated and cured making it microporous. The two joined components, textile support and membrane polymer, are considered to be a filter media. Layers of this media are combined with other components such as spacers to make a spiral membrane element. These elements can range from 40 to 60 inched in length and 6 to 8 inches in diameter. A number of such elements are incorporated in a desalination pressure vessel. Fabric of this construction would generally be classified under sub-heading 5407.61.9905 as woven fabrics, containing 85 percent or more by weight of polyester filaments. However, there is an Explanatory Note to heading 5407 that excludes woven fabrics for technical uses of heading 59.11. This heading does not include: (e) Woven fabrics for technical uses, of heading 59.11. The applicable subheading for the woven polyester substrate will be 5911.40,000, Harmonized Tariff Schedule of the United States (HTS), which provides for Straining cloth of a kind used in oil presses or the like,..The rate of duty will be nine percent ad valorem. There are no textile restraints on goods of this sub-heading. Furthermore, in a recent Ruling of G.S.T Authority of Advance Ruling (“AAR”) In Re: Emmbi Industries Ltd., the product made up of fabric classified under Chapter 54 and when used for technical purpose was classifiable under CTH 5911.

2.5 The applicants have further submitted that, Note 8 to Chapter 59 provides scope of Heading 5911 which covers Textile products and articles, for technical uses, as under: 8. Heading 5911 applies to the following goods, which do not fall in any other heading of Section XI: (a) textile products in the piece, cut to length or simply cut to rectangular (including square) shape (other than those having the character of the products of headings 5908 to 5910), the following only: (i) textile fabrics, felt and felt-lined woven fabrics, coated, covered or laminated with rubber, leather or other material, of a kind used for card clothing, and similar fabrics of a kind used for other technical purposes, including narrow fabrics made of velvet impregnated with rubber, for covering weaving spindles (weaving beams); (ii) bolting cloth; (iii) filtering or straining cloth of a kind used in oil presses or the like, oftextile material or of human hair (iv) flat woven textile fabrics with multiple warp or weft, whether or not felted, impregnated or coated, of a kind used in machinery or for other technical purposes; (v) textile fabrics reinforced with metal, of a kind used for technical purposes; (vi) cords, braids and the like, whether or not coated, impregnated or reinforced with metal, of a kind used in industry as packing or lubricating materials; (b) textile articles (other than those of headings 5908 to 5910) of a kind used for technical purposes [for example, textile fabrics and felts, endless or fitted with linking devices, of a kind used in paper making or similar machines (for example, for pulp or asbestos-cement), gaskets, washers, polishing discs and other machinery parts];

the above explanation provided for Heading 5911 clearly states that the said Heading will cover textile products of woven textile fabrics, coated, covered or laminated with rubber, leather or any other material and shall be in piece either cut to specific length or simply cut rectangularly and used for any technical purpose; the above explanation squarely applies on the Dust Protective Net as the composition, technical specification and the end use of the same is in line with the given application; further, the HSN Explanatory Notes explains Heading 5911 as follows: The textile products and articles of this heading present particular characteristics which identify, them as being for use in various types of machinery, apparatus, equipment or instruments or tools or parts of tools. The heading includes, in particular, those textile articles which are excluded from other headings and directed to heading 59.11 by any specific provision of the Nomenclature (for example, Note 1 (e) to Section XVI). It should be noted however, that certain textile parts and accessories of the goods of Section XVII, such as safety seat belts, shaped motor car body linings and insulating panels (heading 87.08) and carpets for motor cars (Chapter 57), are not classified in this heading.

2.6 The applicants have drawn attention towards the case of Trijama Filterall Pvt. Ltd. vs Collector of Customs,[1992 (62) E.L.T. 566 (Tri.-Del] stating that the Hon’ble Tribunal held that the filter aids in the form of textile fabric for technical use shall be classifiable under Heading 5911. The relevant extract of the judgement is as follows: 6. The entries in both the Tariff Acts of Customs and Excise are pari materia and the headings also identically worded. In the circumstances, the ratio of the Simplex Mills Co. is to be applied to the facts of this case also. The importer has also argued and made out the same points as held in Simplex Mills Co. case. The contention of the learned consultant that note 7(b) of Chapter 59 refers also to textile fabrics of a kind used for technical purposes when they are endless also falling under Chapter 59 carries lot of force in the light of the ratio of the Simplex case referred to above. The note 7(b) of Chapter 59 need not necessarily include textile products in the piece, cut to lengths are simply cut to rectangular (including square) shape and also it need not be an article as has been held by the Collector (Appeals), in view of the example textile fabrics endless given in the bracket in note 7(b) of Chapter 59. We, therefore, allow the appeal by applying the ratio of the above noted case. Therefore, taking into consideration the above interpretation of section notes and classification rulings, the Dust Protective Net being a textile article for technical use will be correctly classified under CTH 59119090.

2.7 The applicants have further submitted that the Dust Protective Net cannot be classified under CTH 39269099 as classification of the Dust Protective Net under Heading 3926 is not supported by well settled principles of classification Rule 1 of the General Interpretation Rules (GIR, in short) lays down that the titles of sections, chapters and sub-chapters are provided for ease of reference only; for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes. The Heading 3926 covers, ‘Other Articles of Plastics and Articles of Other Materials of Headings 3901 To 3914; Office or school supplies; Articles of apparel and clothing accessories (including gloves, mittens and mitts); Fittings for furniture, coach work or the like; Statuettes and other ornamental articles; and Other’; however, in terms of Chapter Notes to Chapter 59, textile articles for technical uses will be classified under CTH 5911; therefore, irrespective of the description of the CTH 3926, the Dust Protective Net being a textile fabric article for technical use and being covered within the Chapter Notes of CTH 5911 will be classifiable under the said heading alone; in this regard, in the case of Commissioner of Central Excise, Nagpur vs Simplex Mills Co. Ltd. [2005 (181) E.L.T. 345 (SC)], it is held that classification of a product is determined according to the terms of the Headings and any relative Section or Chapter Note; General Rules for Interpretation 1 also provides that titles of Sections, Chapters and sub-chapters are provided for ease of reference only; for legal purposes, classification is determined according to the terms of the Headings and any relative Section or Chapter Notes; it is only when such Headings or Notes do not otherwise require that the provisions(2),(3),(4),(5) and (6) of GIR would apply; the subsequent rules can be resorted to only when no clear picture emerges by application of rule (1); in so far as the present case, given that Chapter Notes to Chapter 59 expressly includes textile products having technical use and thus the Dust Protective Net shall be classifiable under CTH 5911 instead of CTH 3926; further, rule 3 (a) of the General Rules for Interpretation lays down that the heading which provides the most specific description(s) shall be preferred to headings providing a more general description; the Heading 3926 provides general description of other articles of plastic whereas, Chapter 59 provides for specific description of CTH 5911 which covers of fabric products being used for technical purposes; therefore, relying on the above principle the description given under the CM! 5911 shall be in preference over the general description given under CTH 3926; in this regard, in the case of Moorco (India) Ltd. Versus Collector of Customs, Madras, [1994 (74) E.L.T. 5 (SC)], the principle of specific over general description was explained; the relevant extract is as follows: The applicability of the rule arises when the goods consisting of more than one material fall in two or more headings. his further clear that each of the classes are mutually exclusive. What is covered in (a) cannot he classified in (b) and (c) operates when neither applies. It is like a residuary clause. The primary question, therefore, is whether the goods manufactured by the appellant fall in clause (a) as if it can be classified with reference to (a) then clauses (b) and (c) would not apply. Clause (a) incorporates the common and general principle that the goods which can be classified specifically with reference to any heading should be placed in that category alone. The specific heading of classification has to be preferred over general heading. The clause contemplates goods which may be satisfying more than one description. Or it may be satisfying specific and general description. In either situation the classification which is the most specific has to be preferred over the one which is not specific or is general in nature. In other words, between the two competing entries the one most nearer to the description should be preferred.

Therefore, in light of the submissions, the applicants have submitted that Dust Protective Net which is PET mesh fabric used for protecting speakers of mobile phones will fall within CTH 5911 and stands excluded from the CTH 3926.

3. A personal hearing in the matter was conducted on 10.01.2024. During the personal hearing, advocate, representing the applicants reiterated the submissions made in the application for advance rulings. He also submitted a copy of their response to comments of the concerned Commissioner. The Authority asked the applicants to inform if they are importing dust protective net, as cut to shape and size part or fabric in the running length? Advocate was also asked if they can show representative sample of the goods in question and inform the cross-sectional area of the filament of which such net said to be woven has been made up of. The representative of the applicant replied that they may be given a week’s time to furnish the information.

4. Comments on the application for advance rulings have been received from the concerned Commissionerate wherein it is inter-alia stated that,

(A) as per chapter note of Chapter 39 and explanatory notes provided in Sub-heading Notes:

1. Within anyone heading of this Chapter, polymers (including copolymers) and chemically modified polymers are to be classified according to the following provisions:

(a) where there is a sub-heading named “other” in the same series:

(1) the designation in a sub-heading of a polymer by the prefix ‘poly’ (for example polyethylene and polyamide --6,6) means that the constituent monomer unit or monomer units of the named polymer taken together must contribute 95% or more by weight of the total polymer content;

(2) the copolymers named in sub-headings 390130,390140,390320, 390330 and 390430 are to be classified in those sub-headings, provided that the co-monomer units of the named co-polymers contribute 95% or more by weight of the total polymer content.

(3) chemically modified polymer are to be classified in the sub-heading named ‘other’, provided that the chemically modified polymers are not more specifically covered by an other sub-heading;

(4) polymers not meeting (1), (2) or (3) above, are to be classified in the subheading, among the remaining subheadings in the series, covering polymers of that monomer unit which predominates by weight over every other single co-monomer unit. For this purpose, constituent monomer units of polymers falling in the same subheading shall be taken together. Only the constituent co-monomer units of the polymers in the series of subheadings Under consideration are to be compared.

(b) where there is no sub-heading named ‘Other’ in the same series:

(1) polymers are to be classified in the sub-heading covering polymers of that monomer unit which predominates by weight over every other single co-monomer unit. For this purpose, constituent monomer units of polymers falling in the same sub-heading shall be taken together. Only the constituent co-monomer units of the polymers in the series under consideration are to be compared;

(2) chemically modified polymers are to be classified in the sub-heading appropriate to the unmodified polymer.

As per importer declaration, fabric is made of PET having more than 95% component, so it seems to be correctly classifiable under CTH 3926.

(B) Whereas Chapter 59 dealt with impregnated, coated, covered or laminated textile fabric, textile articles of a kind suitable for industrial use “except where the context otherwise requires, for the purposes of this Chapter, the expression “textile fabrics” applies only to woven fabrics of Chapter 50 to 55 and headings 5803 and 5806, the braids and ornamental trimmings in the piece of heading 5808 and the knitted or crocheted fabrics of heading 6002 to 6006.

Heading 5911 applies to the following goods, which do not fall in any other heading of Section XI.

(a) textile products in the piece, cut to length or simply cut to rectangular (including square) shape (other than those having the character of the products of headings 5908 to 5910), the following only:

(i) textile fabrics, felt and felt-lined woven fabrics, coated, covered or laminated with rubber, leather or other material, of a kind used for card clothing, and similar fabrics of a kind used for other technical purposes, including narrow fabrics made of velvet impregnated with rubber, for covering weaving spindles (weaving beams);

(ii) bolting cloths;

(iii) filtering or straining cloth of a kind used in oil presses or the like, of textile material or of human hair;

(iv) flat woven textile fabrics with multiple warp or weft, whether or not felted, impregnated or coated, of a kind used in machinery or for other technical purposes;

(v) textile fabrics reinforced with metal, of a kind used for technical purposes;

(vi) Cords, braids and the like, whether or not coated, impregnated or reinforced with metal, of a kind used in industry as packing or lubricating materials;

As declared product is not made of textile material or human hair, the same do not fall under the heading 5911.

(C) The similar case was discussed and decided in the matter of AFR No. 5309-14- 100364; classification of polyethylene (PE) mesh in U.S. Customs & Border Protection Service Port-Houston where PE mesh imported in rolls 6 feet wide and 6000 feet in length. The same can be used in many ways, including industrial, packaging, construction and agriculture. The sample of mesh labeled was wholly of polyethylene type plastic and the same was not made of textile fibre, strip or yarns. In the outcome, it was held that PE mesh is classified in heading 39269090 which provides for “other articles of plastics and articles of other materials of heading 3901 to 3914 and does not fall under the scope of heading 5603.

In light of the above, the comments concluded that item in question is squarely covered under Sub-heading 39269090 and not in any other CTH.

5. The applicant was provided the comments received from the concerned Commissionerate and they submitted response to said comments, wherein, it is inter-alia stated that, (i) Note 2 to Chapter 39 provides for a good which will not be covered under the said Chapter. The Dust Protective Net being a textile article stands excluded and the same being classified under CTH 5911, (ii) the entire basis of the department’s contention that the Dust Protective Net is not made of textile material or human hair and therefore, cannot be classified under CTH 5911, is erroneous. The department has failed to consider that textile material covers within its purview, synthetic fibres which explicitly includes PET as per Note 1(6) to Chapter 54. Same is also evident from Explanatory Notes to Section XI. (iii) In terms of Note 8 to Chapter 59, CTH 5911 will cover textile products of woven textile fabrics, coated, covered or laminated with rubber, leather or any other material and shall be in piece either cut to specific length or simply cut rectangularly and used for any technical purpose. Further, as per Note 1 (6), PET is covered within synthetic fibres which in turn is covered within woven fabrics, (iv) department response that the subject goods made of PET having more than 95% component, thus the same is correctly classifiable under CTH 3926 is completely misplaced, (v) department has failed to consider the subject goods which is mesh fabric, in other words a textile article made up of PET which is a type of synthetic fibre covered under chapter 54, (vi) department has failed to consider the Judgements and Rulings, (vii) department has placed reliance on the U.S. CROSS Ruling HQ H264892 dated 28.02.2018 which held that PE mesh which is spunbonded polymer-based nonwoven web in other words it is two layers of molten polyethylene extruded webs laid over one another in the cross-wise direction and bonded together by thermal bonding method is classified under CTH 3926. However, in the present case, the subject goods consist of woven PET mesh fabric which is completely different from the product under consideration in the said ruling.

6. I have taken into consideration all the materials placed on record in respect of the subject goods including the submissions made by the applicant during the course of personal hearing. I have gone through the comments of the concerned Commissionerate and response of the applicants to the comments. I, therefore proceed to decide the present application regarding classification of Main MIC Dust Protective Net on the basis of information available on record as well as the existing legal framework having bearing on the classification of the subject goods under the first schedule of the Customs Tariff Act, 1975. Though the applicants have sought ruling in respect of the on-going activity however, I note that it has already been decided vide a number of rulings issued by CAAR, New Delhi & Mumbai that issue of ruling in such matters is merited in the interest of certainty for the purposes of classification of goods under the Customs Tariff Act, 1975. Therefore, without deliberating much on the issue, I intend to issue ruling on the instant application for advance rulings.

7. I note that the applicants have inter-alia stated that,

-the main body of the subject goods is made up of Mesh Fabric and back base is of anti-static blue protective film with single sided self-adhesive; the main body of Mesh Fabric as well as back base protective film are made of Poly Ethylene Terephthalate (“PET”), which is the most common thermoplastic polymer resin of the polyester family and is used in fibres for clothing; the subject goods are used for mobile phone speaker to prevent them from dust;

-Dust Protective Net is in the nature of a textile material, used for technical purposes; the subject goods are of precise measurement and are made up of synthetic fibre which is covered within the meaning of woven fabric;

-the technical usage of the subject goods is filtering/protecting dust coupled with the fact that it is made of synthetic fibre which excludes it from the purview of Section XVI and consequently Chapter of 85 of the Customs Tariff Act;

-in the instant case, the Dust Protective Net, made of PET mesh fabric, a woven fabric of Chapter 54 classified under Heading 5407 which covers woven fabrics of synthetic filament; will fall within the meaning of synthetic fibres as per Explanatory Note sand consequently, withing the meaning of Textile fabrics; further, in terms of Note 8 of Chapter 59, when such textile fabrics are used for technical use, they fall under CTH5911 which is evident from Explanatory Notes to CTH 5407;

-the Dust Protective Net which is admittedly small rectangular shaped, made up of woven mesh fabric and a protective layer of PET used in mobile phones for the purpose of filtering and providing protective aid to mobile phone speakers, will be covered under scope of Note 8 to Chapter 59 and hence classifiable under CTH 5911; the cross-sectional dimension as per data sheet of the mesh fabric is 0.0038mm which is less than 1mm. Therefore, the exclusion Mentioned under heading 5407 under the Explanatory Notes, is not applicable to the present case.

8.1 I note that as per Note I of Chapter 39, throughout the nomenclature any reference to ‘plastics’ does not apply to materials regarded as textile materials of Section Xl. Further as per Note 2(p) of Chapter 39, this chapter does not cover, goods of Section XI (textiles and textile articles). Moreover, PET is a plastic as per Explanatory Notes of Chapter 39 of the Harmonized Commodity Description and Coding System of World Customs Organization. And as per Chapter Notes of Chapter 54, polyester is one of the main synthetic fibres and PET is a type of polyester in terms of Explanatory Note to heading 3907. The goods in question are also not covered under Note 1 of Section XI regarding exclusions under the Section. Taking into consideration the foregoing and the declaration of the applicants that the Dust Protective Net is in the nature of a textile material, used for technical purposes; the subject goods are of precise measurement and are made up of synthetic fibre which is covered within the meaning of woven fabric, I feel that inference drawn by the concerned Commissionerate vide their comments against the application for advance rulings that fabric is made of PET having more than 95% component, so it seems to be correctly classifiable under CTH 3926, does not appear to be correct and may lead to wrong classification of the subject goods. Thus, on the basis of the said Section, Chapter Notes and the Explanatory Notes, it can be concluded that goods in question are not articles covered under Chapter 39 but the subject goods merit classification under Section XI.

8.2 As per Explanatory Notes, a few woven fabrics are excluded from the woven fabrics classified under Chapter 50 to 55 and the textile fabric for technical uses classified under heading 5911 are one of them. Further, Note 1 of Chapter 59, provides that, except, where the context otherwise requires, for the purposes of this Chapter the expression ‘textile fabrics’ applies only to the woven fabrics of Chapter 50 to 55 and heading 5803 and 5806 and Note 8 of Chapter 59 provides a list of goods to which heading 5911 applies but with the condition that such goods do not fall in any other heading of Section XI. Since, the subject goods are not covered under any other heading of Section XI and meant for technical use, these goods merit classification under Chapter 59 of the Import Tariff.

8.3 On the basis of foregoing facts and discussions, the subject goods merit classification under Custom Tariff Sub-Heading 59119090 of the First Schedule of the Customs Tariff Act, 1975.

9. I rule accordingly.

(SAMAR NANDA)
Customs Authority for Advance Rulings,
New Delhi

This copy is certified to be a true copy of the ruling and is sent to: -

1. M/s. Vivo Mobile India Pvt. Ltd.10th & 11th Floor, Palm Spring Plaza(Complex), Village- Wazirabad. Sector-54 Gurugram, Haryana

2. The Principal Commissioner of Customs, ACC (Import), New Custom House, IGI Airport, New Delhi-110037

3. The Customs Authority for Advance Rulings, Mumbai, New Custom House, Ballard Estate, Mumbai-400001

4. The Chief Commissioner (AR), Customs Excise & Service Tax Appellate Tribunal (CESTAT), West Block-2,Wing-2, R.K. Puram, New Delhi-110066

5. The Chief Commissioner of Customs, Delhi Customs Zone, New Custom House, IGI Airport Complex. New Delhi-110037

6. Guard file

7. Webmaster.

(Anamika Singh)
Secretary,
Customs Authority for Advance Rulings, New Delhi