2025(01)LCX0085(AAR)

SAMSUNG INDIA ELECTRONICS PVT LTD

decided on 13-01-2025

    CUSTOMS AUTHORITY FOR ADVANCE RULINGS

NEW CUSTOM HOUSE, BALLARD ESTATE, MUMBAI - 400 001

E-MAIL: cus-advrulings.mum@gov.in

The 13^th day of January, 2025

Ruling Nos. CAAR/Mum/ARC/199/2024-25
in
Application No CAAR/CUS/APPL/47/2024 - O/o Commr-CAAR-MUMBAI

Ruling

    M/s Samsung India Electronics Private Ltd (IEC No.: 0595032818) (hereinafter referred to as the ‘Applicant’) filed an application for advance ruling in the Office of Secretary, Customs Authority for Advance Ruling (CAAR) Mumbai on 14.05.2024. The applicant seeks as to whether the ‘Sensor Temp’ which is used in the frost-free refrigerators to maintain the temperature inside the refrigerator at the pre-set levels would fall under CTI 8533 4030 as `Thermistors’ or otherwise.

2. Submission by the Applicant:

2.1 M/s Samsung India Electronics Private Limited (“the Applicant^''), is a Private Limited company engaged in the production and sales of finished products, including TVs, refrigerators, washers, air conditioners, smartphones, and components such as semiconductors and display panels. It serves customers throughout India.

2.2 The applicant is proposing to import “Sensor Temp” (hereinafter referred to as “the sensor/ the subject goods^'').

Function and Composition of the sensor

2.3 The Sensor in question is to be used in Frost-free refrigerators as a temperature sensor to maintain the temperature inside the Refrigerator at the pre-set levels.

2.4 A microprocessor located in Refrigerator. receives the electrical signals corresponding to the changes in he electrical resistance from the sensor. Once preset temperature value is reached. the change in the resistance signals is interpreted by the Electronic Control Unit (ECU) to cut-off the compressor.

2.5 The sensor consists of Thermistor and Epoxy mainly. Thermistor is a resistor whose resistance is dependent on temperature. The term is a combination of ^''thermal^'' and “resistor”. It is made of metallic oxides, pressed into a bead, disk, or cylindrical shape and then encapsulated with an impermeable material such as epoxy or glass.

2.6 There ate two types of thermistors: Negative Temperature Coefficient (NTC) and Positive Temperature Coefficient (PTC). With an NTC thermistor, resistance decreases when the temperature increases. Conversely, when temperature decreases, resistance increases. This type of thermistor is used the most.

2.7 Notably, the sensor is a Negative Temperature Co-efficient sensor (NTC) and not a Varistor Diode or semi-conductor-based resistor.

2.8 The product, thus described as a thermistor is used as an identifiable part of a frost-free refrigerator.

(Picture 2)

3. Applicants interpretation of Law /Facts:

3.1 The Applicant submitted that first schedule to the Customs Tariff Act, 1975 sets out the General Rules of Interpretation (“GRIs”) which are to be applied to determine classification under the Customs Tariff.

3.2 GRI 1 provides that classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the section notes and chapter notes do not otherwise require, the remaining GRIs may then be applied.

3.3 The Section Notes or Chapter Notes and Sub-Heading Notes give detailed explanation as to the scope and ambit of the respective Sections and Chapters. These notes have been given statutory backing and have been incorporated at the beginning of each Chapter.

3.4 In the case of Commissioner of Central Excise vs. Simplex Mills Co. Lid, [2005 (181) E.L.T. 345 (S.Q1, it was held that according to Rule I, titles of Section and Chapters in the Schedules are provided for ease of reference only. For legal purposes, classification shall be determined according to the terms of the headings and any relevant section or Chapter Notes. The other rules for interpretation shall be required only when the relevant Heading or Section Notes are not sufficient to lead to a definitive classification.

Classification under CIA 85334030

3.5 Chapter 85 of the First Schedule to the Customs Tariff Act, 1975 covers goods, described as “Electrical Machinery and Equipment and Parts thereof; Sound Recorders and Reproducers, Television Image and Sound Recorders and Reproducers and Parts and Accessories of Such Articles”.

3.6 The chapter Electrical Equipment Sound Recorders al falls under Section XVI, titled “Machinery and Mechanical Appliances; it: Parts Thereof; Sound Recorders and Reproducers, Television Image and d Reproducers; and Parts and Accessories of such articles^-.

3.7 Chapter Heading 8533 reads as under:

“85.33 - Electrical resistors (including rheostats and potentiometers), other than heating resistors”

3.8 Given the function of the Sensor, it is used in the Frost-Free Refrigerators to maintain the temperature inside the Refrigerator at the pre-set levels. A ECU located in Refrigerator, receives the electrical signals corresponding to the changes in the electrical resistance from the sensor. Once preset temperature value is reached. the change in the resistance signals is interpreted by the ECU to cut-off the compressor.

3.9 The sub-headings under the heading 8533 include the following:

3.10 Sub-heading 8533 40 further specifically provides for Thermistor under CTH 8533 4030.

3.11 At this juncture it is relevant to refer to Note 2 to Section XVI, which governs classification of parts of machinery and equipment of goods of Section XVI. In terms of  Note 2(a) to  Section XVI, parts which are goods covered under any of the headings of Chapter 84 or 85 are in all cases to be classified in that heading only. Only such parts which cannot be classified by application of of Note 2(b) ibid, can be classified by application of Note2(b) ibid, which deals with other identifiable parts of machinery/equipment of Section XVI.

3.12 In the matter of Dolton Cables Ltd. reported in 2005 (181) ELT 373 (SC), the Hon’ble Supreme Court had laid down the ratio of sequential application of Note 2 to Section XVI. In accordance with this ratio, once Note 2(a) is found applicable, recourse to Note 2(b) or 2(c) ibid would not be appropriate.

3.13 It therefore follows that thermistors are covered specifically under CTH 85334030 and hence by application of Note 2(a), classification of the same under CTH 84334030 will be appropriate. Once the classification of the Sensor is determined by application of Note 2(a) ibid, classification of the sensor as other identifiable parts of refrigerator (CTH 8418 9900) by application of Note 2(b) ibid will not be appropriate in view of the ratio laid down by the Hon’ble Supreme Court in the Delton Cables case cited supra.

3.14 A reference to the HSN Explanatory Notes under CTH 8533 also confirms that the thermistors in question will remain under CTH 8533 as shown below:

“(A) Resistors. (resistances) - These are conductors whose function is to provide a given electrical resistance in a circuit (e.g., to limit the current flowing). They vary
The heading includes:

(1) - (4)

(5) Non-linear resistors: depending on temperature (thermistors) with a negative or positive temperature coefficient (usually mounted in glass tubes), and non-linear resistors depending on voltage (Varistors), but not including varistor diodes of heading 85.41.”

3.15 As the thermistor in question is not varistor diodes or semi-conductor-based resistors, classification under CTH 8533 4030 is appropriate.

3.16 Reliance may be placed on the decision of Hon’ble Delhi Tribunal in the matter of M/s Subros Ltd v. CC, New Delhi reported in 2018 (363) ELT 849 (Tri-Del) where the classification of a thermistor used in a refrigerator was approved to be CTH 185334030.

3.17 Reliance may also be placed on the American Cross ruling NY 185734 dated September 13,2002, and N 309090 dated January 30, 2020, where the classification of a similar NTC Thermistors for suitable for most low-cost temperature measurement, control or compensation applications was approved under CTH 8533.40.8070 of US ITC.

3.18 For the reasons discussed above, classification of the sensor under CTH 85334030 will be appropriate.

4. Port of Import and reply from jurisdictional Commissionerate:

4.1 The applicant in their CAAR- l indicated that they intend to import the subject goods i.e. Temperature Sensor at the jurisdiction of Office of the Commissioner of Customs, Air Cargo, Chennai. The application was forwarded to the Office of the Commissioner of Customs, Air Cargo, Chennai Customs for their comments on 10.10.2024.

    The Chennai Air Cargo Customs Commissionerate vide their letter dated 04.01.2025 submitted as per follows:

• The item ” sensor Temp” has only a thermistor encapsulated with epoxy/glass with a dedicated function. As such, based on its components and function, the item has a characteristic of a Thermistor. To be classified under a specific heading or tariff item, the item has a singular function. Hence, the item have a specific entry under Chapter 85.

• As per the note 2(a) to Section XVI the “parts. which are goods included in any of the headings of chapter 84 or 85 (Other than headings 8409, 8431, 8448. 8466, 8473, 8487, 8503. 8522, 8529. 8538 and 8548) are in all cases to be classified in their respective headings. Therefore, the item, being a Thermistor, is appropriately classifiable under the heading 8534030.

• In light of the above, the item “Sensor Temp” is appropriately classifiable under the tariff item 85334030 as claimed by the applicant.

5. Details of Personal Hearing:

5.1 A personal hearing was held on 09.01.2025 at 12.00 PM. Shri P. Sridharan. authorized representative on behalf of the applicant appeared for the hearing. He reiterated the contention filed with their application. He submitted that the subject goods i.e. Sensor Temperature mainly consisting of Thermistor and Epoxy which is an identifiable part of a frost-free refrigerator. It is a Temperature Sensor which maintain the temperature inside the refrigerator at the pre-set levels. He submitted that the subject goods are specifically mentioned under CTI 85334030 as Thermistor in 1975. He relied upon the GRI-1 and Note 2(A) of Section XVI that the goods of heading 84 or 85 (Other than headings 8409. 8431. 8448. 8466. 8473. 8487. 8503. 8522. 8529. 8538 and 8548) are in all cases to be classified in their respective headings.

    Shri indra, Mishra  DC, Group-5A, ACC, Chennai appeared online from the department side for PH. He reiterated their written submission dated 04.01.2025 which endorsed the contention that the 'sensor Temperature’ merit classification CTI 85334030 as proposed by the applicant.

DISCUSSION AND FINDINGS

6.1 I have considered all the materials placed before me in respect of the subject goods. I have gone through the submissions and submission made by the applicant during the personal hearing. I have also gone through the response received from the ACC, Chennai Customs Commissionerate. Therefore. I proceed to pronounce a ruling on the basis of information available on record as well as existing legal framework.

6.2 The Applicant has sought advance ruling in respect of the following questions:

a. Whether the ‘Sensor Temp’ which is used in the frost-free refrigerators to maintain the temperature inside the refrigerator at the pre-set levels would fall under CTI 8533 4030 as ‘Thermistors’ or otherwise?

6.3 At the outset, i find that the issue raised in the Form CAAR- I is squarely covered under Section 28H(2) of the Customs Act, 1962 being a matter related to classification of goods under the provisions of this Act.

6.4 The applicant submitted that the subject goods i.e. Temperature Sensor is to be used in Frost-free refrigerators to maintain the temperature inside the Refrigerator at the pre-set levels. A microprocessor located in Refrigerator, receives the electrical signals corresponding to the changes in the electrical resistance from the sensor. Once preset temperature value is reached, the change in the resistance signals is interpreted by the Electronic Control Unit (ECU) to cut-off the compressor. The sensor consists of Thermistor and Epoxy mainly. Thermistor is a resistor whose resistance is dependent on temperature. The term is a combination of “thermal” and “resistor^-. It is made of metallic oxides, pressed into a bead, disk, or cylindrical shape and then encapsulated with an impermeable material such as epoxy or glass. Notably, the sensor is a Negative Temperature Co-efficient sensor (NTC). The product, thus described as a thermistor is used as an identifiable part of a frost-free refrigerator.

6.5 Before deciding on the issue, let me deliberate on the legal framework prescribed in Customs Tariff Act, 1975, Chapter/ Section notes along with HSN explanatory notes. As per Rule 1 of GRI, 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.

6.6 Now, I take up issue to examine the aspects of classification of the product i.e. Temperature Sensor under CTI 85334030 as proposed by the applicant. The applicant has submitted that the goods in question as “Temperature Sensor” is used in Frost-free refrigerators to maintain the temperature inside the Refrigerator. The Temperature Sensor is a very critical component in frost free refrigerator that act as mind along with the electronic control system. In cooling chambers, the sensor sends the signals when temperature rises above or go below to the set points and activate/stop the compressor.

6.7 I note that the temperature sensor, while essential for maintaining optimal conditions inside a refrigerator, is not a stand-alone item but rather a component used exclusively as part of the main apparatus, i.e., the refrigerator. In this context, the temperature sensor serves as an identifiable part of a frost-free refrigerator, playing a vital role in regulating the internal temperature by working in conjunction with the refrigerator’s cooling system. The Customs Tariff Heading (CTEI) 8418, covers refrigerators and their parts and the relevant portion of the same is reproduced below for ease of reference.

8418 Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps other than air conditioning machines of heading 8412.5.

8418 10 -Combined refrigerator-freezers, fitted with separate external doors or drawers, or combinations thereof:

8418 10 10 -Commercial type

8418 10 9- Other

                -Refrigerators, household type:

8418 21 00 -Compression-type

8418 29 00 -Other

8418 30 - Freezers of the chest type, not exceeding 8001 capacity: 8418 30 10 -Commercial type electrical

8418 30 -Other

8418 40 - Freezers of the upright type, not exceeding 9001 capacity:

8418 40 10 -Electrical

8418 40 90 -Other

8418 50 00-- -Other furniture (chests, cabinets, display counters, show-cases and the like)for storage and display, incorporating or freezing equipment

                -Other refrigerating or freezing equipment; heat pumps:

8418 61 00 -Heat pumps other than air-conditioning machines of heading

8415 8418 69 - other:

8418 69 10 - Ice making machinery

8418 69 20 -- water Cooler

8418 69 30 -Vending machine, other than automatic vending machine

8418 69 40 -Refrigeration equipment or devices specially used in leather industries for manufacturing of leather articles

8418 69 50 - Refrigerated farm tanks, industrial ice cream freezer

8418 69 90 --Other

                -Part:

8418 91 00 -Furniture designed to receive refrigerating or freezing equipment

8418 99 00 -Other

It could be seen from above that the Heading 8418 primarily deals with Refrigerators, freezers and other refrigerating or freezing equipment, electric or other; heat pumps other than air conditioning machines of heading 8412.5 and parts thereof. The heading is divided into six major sub-headings namely (a) Combined refrigerator-freezers, (b) Refrigerators, household type (c) Freezers of the chest type (d) Freezers of the upright type (e) Other refrigerating or freezing equipment, heat pumps and (f) parts. Thus, it is pertinent to mentioned that Chapter Heading 8418 also covers “parts of the refrigerator, freezer and other refrigerator or freezer equipment”. There could be no dispute in the present case that the items in question is directly usable and identifiable as parts of refrigerator.

6.8 It is seen that HS Explanatory Notes to headings 8418 as regards parts falling thereon, stipulates that classification of parts of machines of heading 8418 are: "Subject to the general provisions regarding the classification of parts (see the General Explanatory Note to Section XVI)...".

    Further, it Would also be useful to refer to Note 2 of Section XVI of the Tariff Act. 1975 which provides for rules to be followed while classifying "parts of machines' falling under Chapters 84 and 85. The relevant part of the Section Note 2 is reproduced below:

“2. Subject to Note I to this Section, Note I to Chapter 84 and Note I to Chapter 85, parts of machines (not being parts of the articles of heading 8484, 8544, 8545, 8546 or 8547) are to be classified according to the following rules:

(a) parts which are goods included in any of the headings of Chapter 84 or 85 (other than headings 8409, 8431, 8448, 8466, 8473, 8487, 8503, 8522, 8529, 8538 and 8548) are in all cases to be classified in their respective headings;

(b) other parts, if suitable for use solely or principally with a particular kind of machine, or with a number of machines of the same heading (including a machine of heading 8479 or 8543) are to he classified with the machines of that kind or in heading 8409, 8431, 8448, 8466, 8473, 8503, 8522, 8529 or 8538 as appropriate. However, parts which are equally suitable for use principally with the goods of headings 8517 and 8525 to 8528 are to be classified in heading 8517;

(c) all other parts are to be classified in heading 8409, 8431, 8448, 8466, 8473, 8503,8522, 8529 or 8538 as appropriate or, failing that, in heading 8487 or 8548″

6.9 It is seen that parts which are goods included in any of the Heading of Chapters 84 or 85, other than certain specified Chapter Heading, are in all cases to be classified in their respective headings as per Note 2(a) of the Customs Tariff Act, 1975. Thus, there is a condition to classify any part in its respective heading that it should be goods which is included in any heading of Chapter 84 or 85 which means it should be clearly listed in Chapter 84 or 85.

6.10 I note that the temperature sensor, which primarily consists of an NTC thermistor, functions as an electrical resistor whose resistance varies with temperature. As the temperature inside the refrigerator changes, the resistance of the NTC thermistor also adjusts accordingly-decreasing as the temperature rises and increasing as the temperature falls. Thus, the product i.e. Temperature Sensor, as part of the refrigeration system, fall within the broader group of electrical resistors.

6.11 The Customs Tariff Heading (CTH) 8533 specifically covers “Electrical resistors (including rheostats and potentiometers), other than heating resistors”. As the NTC thermistor is not designed for heating purposes but rather for temperature sensing, it is correctly classified under this heading.The relevant portion of Customs Tariff Heading (CTH) 8533 is reproduced as under:

6.12 The relevant Explanatory Notes to Heading 8533 is extracted hereunder:

“(A) Resistors (resistances). These are conductors whose function is to provide a given electrical resistance in in a circuit (e.g., to limit the current flowing). They vary greatly in size and shape, and in the materials of which they are made. They may be made of metals (in the form of bars, shapes or wire, often coiled in bobbins) or of they carbon in the _.form of rods, or of carbon, silicon carbide, metal or metal oxide film. They may be obtained in the form of individual components by a printing process. Certain resistors may be fitted with a number of terminals allowing the whole or part  to be included in the circuit.
The heading includes:

(1) Oil immersed resistors.

(2) Carbon resistance lamps, in the forma of an electric light bulb but with a special carbon filament; however, carbon filament lamps for lighting purposes are excluded (heading 85.39).

(3) Barretters consisting of iron filaments assembled in a glass tube filled with hydrogen or helium; these have the property of varying automatically within certain units and so keeping the current constant.

(4) Standard resistors used for comparison and measuring purposes (e.g., in laboratories); also resistance boxes consisting of a number of such resistors assembled in a box with switching or terminal arrangements_.* connecting any required combinations of the resistors into the circuit.

(5) Non-linear resistors: depending on temperature (thermistors) with a negative or positive temperature coefficient (usually mounted in glass tubes), and nonlinear resistors depending on voltage (varistors/VDR), but not including varistor diodes of heading 85.41.

(6) Resistors known as “strain gauges” being the sensitive elements of a strain measuring instrument.

The heading excludes:

(a) Heating resistors (heading 85.16 or 85.45).

(b) Light dependent resistors (heading 85.41).

(B) Rheostats. These are variable resistors with a sliding contact or other means enabling the value of resistance in the circuit to be varied at will. They include, slide wire rheostats with a cursor sliding over a resistance coil; step-by-step rheostats; hydro-rheostats with movable electrodes immersed in a liquid conductor; automatic rheostats (e.g., with minimum or maximum current or voltage operating mechanisms); and centrifugal rheostats.

Certain rheostats are designed for particular purposes (e.g., theatre dimmers used in a lighting circuit to extinguish the lighting slowly; and motor starters and controllers consisting of a number of resistors with the necessary switching arrangement for switching in or out one or more resistors in the motor circuit). Nevertheless, they remain classified here.

(C) Potentiometers. These consist of a fixed resistor between two contacts and a sliding tapping which can make contact on any point of the resistor.

PARTS

Subject to the general provisions regarding the classification of parts (see the General Explanatory Note to Section XVI), parts of the resistors of this heading are also classified here.”

6.13 It could thus be seen from the HSN ENs extracted above, the heading 8533 inter-al ia covers Electrical resistors, other than heating resistors. Resistor depending on temperature known as thermistors with a negative or positive temperature coefficient (usually mounted in glass tubes) are also specifically covered under the category of Non-linear Resistor.

    The product in question primarily consists of an epoxy-coated NTC thermistor, a type of electrical resistor whose resistance changes in response to temperature variations. As an NTC thermistor. it operates as a non-linear resistor, meaning that its resistance decreases as the temperature increases, and vice versa. This non-linear behavior is a defining characteristic of NTC thermistors, making them highly sensitive to temperature changes. Given that the thermistor functions as a resistor and exhibits non-linear resistance characteristics, it is classified under the heading 8533 for “Non-linear resistors”.

6.14 Before delving into the specifics, let’s first understand what a thermistor is in a general sense. A thermistor is a type of resistor whose resistance changes significantly with changes in temperature. The term “thermistor” comes from a combination of the words “thermal” (relating to heat) and “resistor’ (a component that resists the flow of electrical current). Unlike standard resistors, whose resistance remains relatively constant, a thermistor’s resistance varies in a predictable way based on the temperature around it.

6.15 In the present case, the Temperature Sensor is a type of a thermistor that is a special kind of resistor whose resistance varies with temperature. Unlike standard resistors. whose resistance is relatively stable, the resistance of a thermistor changes significantly as the temperature changes. This characteristic makes thermistors ideal for temperature measurement and control applications. Thermistors are made from semiconductor materials, and their temperature-resistance relationship can be either negative or positive:

(i) NTC (Negative Temperature Coefficient) thermistor: In these thermistors, as the temperate increases, the resistance decreases. NTC thermistors are commonly used in temperate sensing applications because their resistance change is predictable and relatively rapid with temperature fluctuations.

(ii) PTC (Positive Temperature Coefficient) thermistor: These thermistors exhibit the opposite behavior-when the temperature increases, their resistance also increases. PTC thermistors are often used for applications like overcurrent protection or self-regulating heating elements.

6.16 From the explanation above, it is clear that the Temperature Sensor is a NTC Thermistor because its resistance decreases as the temperature increases, and vice versa. This characteristic is defining feature of NTC thermistors, which makes them ideal for temperature sensing applications, including in refrigerators. air conditioners, and other temperature-sensitive devices. Further, the CTI (Customs Tariff Item) 85334030 specifically provides for thermistors. which includes components such as the NTC thermistor that is used for temperature measurement and control. As the subject goods are NTC thermistors, which function as temperature sensors due to their temperature-dependent resistance properties, they clearly fall under the category of thermistors as outlined in CTI 85334030 of the First Schedule of the Customs Tariff Act, 1975.

    Therefore, the subject goods, being NTC thermistors used for temperature sensing. are correctly classifiable under CTI 85334030 (Thermistor) of the First Schedule of the Customs Tariff Act, 197′ by virtue of Note 2(a) to Section XVI and Explanatory Notes to Chapter Heading 8533.

7. I placed reliance on the decision of Hon’ble Delhi Tribunal in the matter of CC, Patparganj Vs. Mts^. Subro. Ltd v. CC, New Delhi ‘Final Order No. 58389/2017, dated 12-12-2017], wherein the Tribunal upheld the decision of Commissioner(Appeal) and held that the resistors are classifiable under CTH 8533.

    I also p aced reliance on the decision of Hon’ble Delhi Tribunal in the matter of M/s Subros Ltd v. CC, Ne Delhi reported in 2018 (363) ELT 849 (Tri-Del) where the assesses was classifying the thermistor or auto-air conditioner under CTI 85334030. The Department has sought to classify them under C 118415 as parts of auto-air conditioner. The Hon’ble Tribunal reject the classification proposed by Department.

    These decisions are significant because it highlights that thermistors, due to their specific function and classification as electrical resistors (under CTI 85334030), should be classified based on their electrical properties rather than simply as parts of a broader apparatus like refrigerator or air conditioners and the same is backed up by the specific entry given in the Customs Tariff Act, 1975.

8. In view of the above. it can be concluded that the subject goods i.e. Temperature Sensor being apart of the refrigerator is classifiable under CTH 8533 (Electrical resistors (including rheostats and potentiometers), other than heating resistors), more specifically under CTI 85334030 (Thermistors) of the Customs Tariff Act, 1975 by application of Rule 1 of GRI, Explanatory Notes to Chapter Heading 84.18 and 85.33 and Note 2(a) of Section XVI of Customs Tariff Act, 1975.

9. On the basis of foregoing discussions and findings, I reach to conclusion that the product i.e. Temperature Sensor merit classification under CTH 8533 (Electrical resistors (including rheostats and potentiometers), other than heating resistors), more specifically under CTI 85334030 (Thermistors) of the First Schedule of Customs Tari fT Act, 1975.

10. I rule accordingly.

(Prabhat K. Rameshwaram)          
Customs Authority for Advance Rulings, Mumbai

F. No. CAAR/CUS/APPL/47/2024-O/oCommr-CAAR-Mumbai             Dated: 13-01-2025

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

1. M/s Samsung India Electronics Private Ltd..
Plot No. P-1, SIPCOT Industrial Park Phase-2.
Walajahbad Road, Sunguvarchatram Post.
Sriperumudur Taluk. Kancheepuram
District. Tamil Nadu-602 106.
(Email: k.suresh@samsung.com}

2. Office of the Commissioner of Customs.
Chennai-VII Commissionerate. New Custom House.
Air Cargo Complex. Meenambakkam, Chennai-600016

3. The Customs Authority for Advance Rulings.
Room No. 24. New Customs House.
Near IGI Airport, New Delhi-110037.
Email: cus-advrulings.del@gov.in

4. The Principal Chief Commissioner of Customs. Mumbai Customs Zone-I. Ballard Estate.
Mumbai -400001.
Email: ccu-cusmum1@nic.in

5. The Commissioner (Legal). CB1C Offices. Legal/CX.8A. Cell. 5th floor. Hudco Vishala Building, C-Wing, Bhikaji Cama Place. R. K. Puram. New Delhi - 110066.

Email: anishgupta.irs@gov.in, commr.legal-cbec@nic.in

6. The Member (Customs). Central Boards of Indirect Taxes & Customs. North Block. New Delhi-110001.
Email: mem.cus-cbec@nic.in

7. The Webmaster. Central Boards of Indirect Taxes & Customs
Email: webmaster.cbec@icegate.gov.in

8. Guard file.

(Vivek Dwivedi)            
Dy. Commissioner & Secretary
Customs Authority for Advance Rulings.
Mumbai