2025(04)LCX0118(AAR)

Netlink ICT Private Limited

decided on 21-04-2025

Customs Authority for Advance Rulings 

New Custom House, Ballard Estate, Mumbai - 400 001

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

N.B.:

1. A copy of this order made under sub-section (2) of Section 28-1 of the Customs Act, 1962 is granted to the concerned free of charge.

2. Any appeal against this Advance Ruling order shall lie before the High Court of concerned jurisdiction, within 60 days from the date of the communication of such ruling or order.

3. The advance ruling pronounced by the Authority under Section 28 -1 shall remain valid for three years or till there is a change in law or facts on the basis of which the advance ruling has been pronounced, whichever is earlier.

4. Where the Authority finds that the advance ruling was obtained by the applicant by fraud or misrepresentation of facts, the same shall be declared void ab initio.

Advance Ruling

M/s. Netlink ICT Private Limited (IEC No.: 1015002943) (hereinafter referred to as ‘the Applicant’) filed an application (CAAR-1) for advance ruling in the Office of Secretary, Customs Authority for Advance Ruling (CAAR) Mumbai. The said application was received in the secretariat of the CAAR, Mumbai on 08.01.2025 along with its enclosures in terms of Section 28H(1) of the Customs Act, 1962(hereinafler referred to as the ‘Act also’). The Applicant is seeking advance ruling on the issue of classification of the Interactive Flat Panels under CTI 84714190 of the First Schedule of the Customs Tariff Act, 1975.

2. Submission by the Applicant:

2.1 MIs. Netlink ICT Private Limited (“the Applicant”), a Private Limited company is importer, traders and manufacturers of “Fiber to the home” (hereinafter referred to as “FTTH”) products. The Applicants intend to import the following “Interactive Flat Panels (hereafter referred to as “Interactive Flat Panel”) under its brand name ‘Hynits’ from China and sell it further to their distributors/consumers.

HV Series Y55A10/FS-A06
HV Series Y65A10/TS-A06
HV Series Y75A10/TS-A06
HV Series Y85AIOiTS-A06
HV Series Y86A10/TS-A06
HV Series Y98A10/TS-A06

2.2 The Interactive Flat Panels comprise of ADS (Advanced Super Dimension Switch) Panel with an LED backlight and 4K HDR picture quality. The subject goods facilitate seamless web conferences and virtual meetings. It can also be utilized as a smart whiteboard and allows users to perform multi-touch gestures on the interactive whiteboard screen.

2.3 The Interactive Flat Panel contains storage and processing capabilities with Android features. They have an in-built Central Processing Unit (CPU) and RAM for the execution of programs. They have a pre-installed operating system, namely, Android 13. In addition, it has an OPS(Open Pluggable Specification) Slot which can be used to download and operate other operating systems. The mentioned products can access the Internet either by connecting to an external USB Wi-Fi dongle or via a LAN cable. They are also compatible with monitors, laptops, and PC’s and allow input to flow both from these products to the connected devices and vice versa.

2.4 The Interactive Flat Panel further enables the user to download and install new programs & applications according to the requirements of the user. It offers advanced features such as multitouch interaction, wireless screen share and on-screen keyboard along with built-in tools such as a calculator and stopwatch.

2.5 The product features ultra-fine touch technology for enhanced precision in writing and faster processing. It comes equipped with a dual-head stylus, remote control, power cable, Wi-Fi antenna, wall bracket and anti-glare tempered glass with a flicker-free display. It also includes slots for HDMI, LAN, USB, RS232 (a standard communication interface to facilitate serial data exchange between devices. The RS-232 standard defines how data is transmitted between devices, including voltage levels, timing, and handshaking (flow control) mechanisms. It was widely used to connect periphetals like printers, modems, and industrial machines to computers) and audio ports.

2.6 The product specifications are summarized as follows:

 3. Applicants interpretation of Law/Facts:

3.1 The Applicant submit that Chapter 84 of the Customs Tariff Act, 1975 deals with nuclear reactors. boilers, machinery, and mechanical appliances; parts thereof, it may be noted that tariff heading 8471 provides for automatic data processing machines and units thereof, magnetic or optical readers, machines for transcribing data on to data media in coded form and machines for processing such data, not elsewhere specified or included.

3.2 Chapter Note 6(A) outlines the criteria for classifying a product as an “automatic data processing machine”. It can be seen that an automatic data processing machine is defined as any device capable of storing a processing program, being freely programmable, performing arithmetic operations, and executing logical decisions without human intervention. Additionally, it must include a Central Processing Unit (CPU), an input unit, and an output unit, either housed together or interconnected as separate components.

3.3 To qualify for classification under CTH 8471 as an automatic data processing machine (ADPM), the product must meet the criteria outlined in Note 6(A) of Chapter 84. It is asserted that the Interactive Flat Panel meets all the necessary prerequisites and conditions, as outlined in the tabe below.

3.4 From the above, it can be understood that the Interactive Flat Panel satisfies all the requirements as mandated under Note 6(A) to Chapter 84 of the Customs Tariff Act, 1975. Accordingly, the Interactive Flat Panel qualify as an “automatic data processing machine” as defined under Note 6(A) of Chapter 84.

3.5 It is undisputed that the Interactive Flat Panel qualifies as an automatic data processing machine incorporating in a single housing at least a central processing until and an input/output unit, whether or not combined. However, Interactive Flat Panel are neither in the nature of a microcomputer (small or personal computer) covered under CTH 8471 41 10 nor in the nature of a large or main frame computer covered under CTH 8471 41 10. Accordingly, the Interactive Flat Panel is classifiable under the residual tariff heading “8471 41 90-Other” and is subject to a nil rate of duty.

3.6 The Applicants submit that there are numerous advance rulings concluding that Interactive Flat Panel is classifiable under the residual tariff heading “8471 41 90-Other. In the case of M/s Compuage Infocom Ltd. [2022-VIL-57-AAR-CU] it was held that the Interactive Flat Panel is classifiable under the residual tariff heading “8471 41 90-Other.

3.7 A similar view was adopted in the following rulings as well:

(i) M/s Viewsonic Technologies India Pvt. Ltd.-Advance Ruling No. CAAR/Mum/ARC/19/2024 dated 15.02.2024

(ii) M/s Supertron Electronics Private Limited-Advance Ruling No. CAAR/Del/Supertron/10/2023 dated 08.05.2023

(iii) Ingram Micro India Private Limited vs. Principal Commissioner of Customs (Import), New Delhi [(2023) 2 Centax 62 (Tri.-Del.)}

(iv) In Re: Next Education India Private Limited [2022 (60) G.S.T.L 483 (A.A.R- GST-Telangana)]

4. Port of Import and reply from jurisdictional Commissionerate:

4.1 The applicant in their CAAR-1 indicated that they intend to import the subject goods i.e. Interactive Flat Panel at the jurisdiction of Office of the Commissioner of Customs, Import-II Chennai. The application was forwarded to the Office of the Commissioner of Customs, Import-II, Chennai for their comments on 13.01.2025.

    The concerned jurisdictional Commissionerate vide their letter dated 04.04.2025 has submitted as follows:

• Interactive Flat-Panel Display (IFPD) is a large-format touch-screen display ideal for meeting rooms, class rooms and collaborative spaces. It is a replacement for clunky or outdated projector technology with a higher-quality display, enhanced connectivity, and built- in software solutions. These solutions are perfect for business opportunities, educational pursuits, and even at home leisure. In a nutshell on IFPD-short for Interactive Flat PaneI Display, it a type of interactive whiteboard (IWB). An IWB is a large electronic display that has a touch-screen and is able to access, manipulate, and interact with electronic files. They easily and beautifully handle the highly collaborative needs of today’s office space with 20 points of touch and wide viewing angles with options for ultra-fine 4K resolution and the ability to present a surprisingly natural handwriting experience. IFPDs support communication and collaboration in ways never before possible in the meeting room. Most IFPDs have a number of built-in software integrations, like Cast, Chrome etc which come pre- installed on all displays. An interactive flat panel does not require a projector because all hardware is contained in a flat panel display,
   

• there are various types of Interactive Devices and known by various names in the Industry i.e., Interactive Whiteboard/ Smartboard, Interactive Flat Panel Display, Interactive Intelligent t Panels etc. is an advanced technology used in classroom teachings, conferences etc. The Interactive Display Systems can be used to present documents, information and videos to different groups, educational purposes i.e., e-learning for example to a group of students in a classroom or during a meeting in a business environment
   

• as per Note 6(D) to Chapter 84, Heading 8471 does not cover the monitors and projectors not incorporating television reception apparatus when presented separately even if they meet alI the conditions mentioned in Para(C) of the said Note. Further, para (E) states that machines, instruments or apparatus incorporating or working in conjunction with an automatic data processing machine and performing a specific function other than data processing are to be classified in the headings appropriate to their respective functions or, failing that, in residual headings.
   

• The subject goods are not merely an ADPM and in fact it has many other additional inbuilt features with the main purpose to interact through display as per the intended use i.e., training, conferences, educational purposes, teaching via e-learning etc. The goods are mainly Display devices incorporating and working in conjunction with an automatic data processing machine i.e., inbuilt CPU. Therefore, the primary function of the goods is to display the given input data/ images/pictures/videos etc.
   

• ADP machines performing specific functions other than Data processing are required to be classified as per their respective functions. Even though the functions of an ADP machines are inbuilt, the subject goods viz., Interactive Flat Panels being primarily used as Display System cannot be considered as a simple input or output device and is to be identified with its primary function of display by applying Note 6 (E) of Chapter 84 Note as mentioned above.
   

• The appropriate heading for classification of the impugned goods therefore shall be 8528 which covers – “Monitors and projectors, not incorporating television reception apparatus: reception apparatus for television, whether or not incorporating radio broadcast receivers or sound or video recording or reproducing apparatus. Since, the description mentioned in the application is “Interactive Flat Panel”, the main function of subject goods is interaction through display. Essentially, it acts as a display monitor, meaning that you can select to view documents, videos and even web links on a larger scale.
   

• Further, as per Chapter Note 3 to Section XVI states that “Unless the context otherwise requires, composite machines consisting of two or more machines filled to form a whole and other machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function”. I find that the primary function of the subject goods is display and are also marketed as products with efficient display qualities, touch screen, write or draw on screen.
   

• the subject goods cannot be considered as an Automatic Data Processing machine under CTH 8471. It is pertinent to mention here that even Cellular Android Phones do incorporate all the functions of an ADP Machine and also works on Android OS, yet the same is classified under cellular phones as the primary function is communication. Applying the same analogy, the principle function of the item under import is to interact through display and hence the impugned goods are classifiable under sub-heading 8528 5900 which deals with other monitors.
   

• In case of Commissioner of Customs (Import & General), New Delhi Vs Integral Computer Lid 2016 (337) E.L.T. 580 (Tri-Del) dated 07.04.2016 the Hon’ble Tribunal has held that “Interactive Electronic White Board” is a teaching device mainly used for class room teaching or in conferences and meetings and work and gets the display function by combined action with a computer and projector cannot be considered as a simple input or output device and is to be identified with its primary function of display and has classified the goods under sub-heading 8528 5100 i.e., other monitors (now CTI 8528 5900)”. The issue is squarely covered in the present case.

5. Details of Hearing

5.1 A hearing was conducted on 04.04.2025 at 01:00 PM. Shri Antony Saroj, Authorized Representative (AR), appeared online on behalf of the applicant and reiterated the contentions submitted in the application. He submitted that the subject goods, namely Interactive Flat Panel Displays, are equipped with a CPU, RAM, Android OS or another operating system, and meet all four criteria of an Automatic Data Processing (ADP) Machine as defined under Note 6(A) to Chapter 84 of the Customs Tariff. In support of his submission, he also relied upon Advance Rulings previously issued by this Authority.

During the hearing, the Authorized Representative was informed that a change in the classification of Interactive Flat Panel Displays under Customs Tariff Item (CTI) 8528 59 00 was introduced in the Union Budget 2025-26, and such decision is binding on this Authority.

Nobody appeared on behalf of the department for the hearing.

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 made by the applicant during the hearing. 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 question:

a. Whether the product i.e. Interactive Flat Panel is classifiable under CTI 84714190 of the First Schedule of the Customs Tariff Act, 1975 or otherwise.

6.3 At the outset, I find that the issue raised in the question in the Form CAAR-1 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 stated that the Interactive Flat Panels feature an ADS panel with LED backlight and 4K HDR quality. They support web conferencing, virtual meetings, and function as smart whiteboards with multi-touch capability. The panels include built-in CPU, RAM, and Android 13 OS, with storage and processing features. They also have an OPS slot for installing other operating systems and can connect to the internet via USB Wi-Fi dongle or LAN. The devices are compatible with monitors, laptops, and PCs, allowing two-way input and interaction.

6.5 In this regard, I find that as per the recent changes in Chapter 85 of the Customs Tariff Act following the Govt. of India Budget 2025 on 1St February, 2025, the Basic Customs Duty (BCD) on Interactive Flat Panel Displays (CBU) classified under CTH 85285900 has been increased from 10% to 20%. The relevant portion of the Budget Changes are extracted below for ready reference:

III. AMENDMENTS TO DUTY RATES IN FIRST SCHEDULE TO THE CUSTOMS TARIFF ACT, 1975

 6.6 The chapter-wise changes pertaining to Customs Tariff rates and HSN amendments have been summarized in Annexure-I to the D.O. Letter F. No. 334/3/2025-TRU, dated 1st February 2025 <https://www.indiabudget.gov.inidocken/dojstrul.pdf>, issued by TRU-I, CBIC, New Delhi, and circulated to all field formations for necessary information and action. The relevant changes made under Chapter 85 are extracted below for ease of reference: https://www.indiabudget.gov.inidocken/dojstrul.pdf

Chapter 85:

1) BCD is being increased from 10% to 20% on Interactive Flat Panel Displays (CBU) classified under tariff item 8528 59 00. [Clause 98(b) of the Finance 13×11, 2025 read with Third Schedule refers]. By virtue of declaration under the Provisional Collection of Taxes Act, 2023, this increase will come into force with effect from midnight of 1^st February/rdFebruary, 2025. [Clause 98(a) of the Finance Bill. 2025 read with Second Schedule refers].

However, all goods classified under tariff item 8528 59 00, other than Interactive Flat Panel Display (CBU) will continue to attract 10% BCD under S.No 515C of Notification No. 50/2017-Customs dated 30 June, 2017 amended by Notification No. 5/2025 Customs dated 1^st February,2025

2) BCD is being reduced to 5% on Open Cell with or without touch classified under heading 8524 for manufacture of Interactive Flat Panel Display module. [ S.No. 515AA of Notification No. 50/2017-Customs dated 30th June ,2017 as amended by Notification No.5/2025 -Customs, dated 1″ February, 2025 refers].

3) BCD is being reduced to 5% on Touch glass sheet and Touch sensor PCB classified under heading 8529 for the manufacture of Interactive Flat Panel Display modules. [S.No 515 D of Notification No. 50/2017-Customs dated 30th June, 2017 as amended by Notification No.5/2025 -Customs, dated 1^st February, 2025 refers.].

Thus a graded duty structure is being put in place to incentivize domestic manufacture of Interactive Flat Panel Displays as below:

6.7 Furthermore, the Tax Research Unit (TRU), Department of Revenue, CBIC, New Delhi, has issued Circular No. 12/2025-Customs dated 7th April 2025, providing clarification regarding the classification and applicable Basic Customs Duty (BCD) on Interactive Flat Panel Displays (IFPDs) and other types of monitors. The said circular has clarified that Interactive Flat Panel Displays are classifiable under tariff item 8528 59 00 and are subject to Basic Customs Duty at the rate of 20%. The relevant extract from the circular is reproduced below for reference.

Circular No. 12/2025-Customs

CBIC-190354/47/2025-TRU Section-CBEC
Government of India
Ministry of Finance
Department of Revenue
Tax Research Unit

North Block, New Delhi Dated: 07th April, 2025

To,

All Principal Chief Commissioner/Chief Commissioner of Customs/Customs (Preventive),
All Principal Chief Commissioner/Chief Commissioner of Customs & Central Tax,
All Principal Commissioner/Commissioner of Customs/Customs (Preventive),
All Principal Commissioner/Commissioner of Customs & Central Tar,
All Principal Director Generals/Director Generals under CBIC

 Subject: Clarification on the classification and applicable Basic Customs Duty (BCD) on Interactive Flat Panel Displays (IFPDs) and other monitors – reg.

************,

Prior to 2025-26 Budget, all goods classified under tariff item 85285900 attracted Basic Customs Duty (BCD) of 10%. In the 2025-26 Budget, BCD on Interactive Flat Panel Displays (IFPDs) classified under tariff item 85285900 was increased from 10% to 20% with effect from 2nd February, 2025 vide Section 103 (a) read with Second Schedule of the Finance Act, 2025 and declaration under the Provisional Collection of Taxes Act, 2023. However, all goods classified under tariff item 85285900 other than IFPD was continued at 10% BCD with IGCR condition vide entry at S. No. 515C of the Notification No. 50/2017-Customs dated 30.06.2017. This was to prevent circumvention of the higher duty on IFPDs. The intent was not to charge 20% on monitors other than IFPDs.

2. Industry associations have sought clarification regarding compliance with IGCR condition under said entry at S. No. 515C of the Notification No. 50/2017-Customs since the imported monitors are not used in further manufacturing activity. After examining the issue, vide Notification No. 23/2025-Customs dated 04.04.2025, the entry at S. No. 515C of the Notification No. 50/2017-Customs dated 30.06.2017 has been amended to remove the IGCR condition. For distinguishing IFPDs from monitors other than IFPDs, based on the technical inputs from Ministry of Electronics and Information Technology (Ivieiti9 received vide their OM dated 13.03.2025, the following may be used as a technical guide:

3. References have also been received from field formations and Industry association seeking clarification regarding the appropriate classification of the IFPDs vis-a vis monitors, other than IFPDs and parts of IFPDs, in light of inconsistency in classification practice of such goods. To ensure uniformity in tariff. classification of the IFPDs and other monitors, it is hereby clarified that both IFPDs and monitors other than IFPDs are classifiable under tare’ item 85285900. It is further clarified that parts of IFPDs, such as Touch Glass Sheets and Touch Sensor PCBs, shall be Classified under HS 8529 attracting BCD rate of 5% as per entry at Sr. No. 515D of the Notification No. 50/2017-Customs dated 30.06.2017.

4. Difficulties, if any, faced in the implementation of these instructions may be brought to the notice of the Board.

5. Hindi version will follow.

****************

6.8 In light of the recent amendments to Chapter 85 of the Customs Tariff Act, as introduced in the Finance Bill 2025 on I st February 2025, and the subsequent clarification issued by the Board vide Circular No. 12/2025-Customs dated 7th April 2025, it is clearly established that Interactive Flat Panel Displays are appropriately classifiable under Customs Tariff Item (CTI) 8528 59 00 of the Customs Tariff Act, 1975.

6.9 Section 15 1 A of the Customs Act empowers the Board to issue orders, instructions, and directions to officers of customs, as it may deem necessary, for the purpose of ensuring uniformity in the classification of goods and the levy of duty thereon. It further mandates that all customs officers and other persons engaged in the implementation of the Act are required to observe and comply wit such orders, instructions, and directions issued by the Board.

6.10 The Honible Supreme Court, in the case of CCE v. Mire:: Chemical Industries [2002 (139) E.L.T. 3 (S.C.)] held that circulars issued by the Central Board of Excise and Customs are binding on the Revenue authorities. This position was reaffirmed by the flonible Supreme Court in CCE, Balpur v. Ratan Melting & Wire Industries [2008 (12) S.T.R. 416 (S.C.)], wherein it reiterated that circulars issued by the Board are binding on the departmental officers. Thus, it is a well-settled legal principle that the circulars issued by the Board are binding on the Revenue.

6.11 I have also examined the specifications of the subject goods, i.e., Interactive Flat Panel, as submitted by the applicant in their application. Upon review, I find that the specifications are identical/similar to those of the Interactive Flat Panel Display described by the Board in Circular No. 12/2025-Customs dated 7th April 2025.

6.12 in view of the above discussions, I observe that the subject goods “Interactive Flat Panel”, is to be classified under Customs Tariff Item (CTI) 8528 59 00 of the Customs Tariff Act, 1975, in terms of the provisions made in the Finance Bill, Budget documents and as per the clarification provided in Circular No. 12/2025-Customs dated 7th April 2025.

7. The applicant has relied upon various advance rulings and case laws, including those in the cases of M/s Compuage Infocom Ltd [2022-VIL-57-AAR-CU], M/s Viewsonic Technologies India Pvt. Ltd. [CAAR/Mum/ARC/19/2024 dated 15.02.2024], M/s Supertron Electronics Private Limited [CAAR/Del/Supertron/10/2023 dated 08.05.2023], Ingrain Micro India Private Limited vs. Principal Commissioner of Customs (Import), New Delhi [(2023) 2 Centax 62 (Tri.-Del.)], and Next Education India Private Limited [2022 (60) G.S.T.L. 483 (A.A.R.-GST-Telangana)].

In this regard, it is observed that advance rulings are binding only on the applicant to whom they are issued and on the jurisdictional customs authorities. Furthermore, as per the provisions of Section 283(2) of the Customs Act, an advance ruling shall remain valid unless there is a change in law or in the facts on the basis of which such ruling has been pronounced.

In the present case, there has been a significant change in law pursuant to the recent amendments to Chapter 85 of the Customs Tariff Act, introduced through the Finance Bill 2025 on 1st February 2025 and subsequent change made. These amendments have provided a specific tariff entry for Interactive Flat Panel Displays under CTI 8528 59 00 of the Customs Tariff Act, 1975 and incorporated in the Board Circular dated 7th April, 2025.

Accordingly, in view of the change in legal provisions, the advance rulings and case laws relied upon by the applicant become irrelevant and are not applicable.

8. The jurisdictional Commissionerate has contended that the subject goods, i.e. Interactive Flat Panel is classifiable under CTI 85285900 (Other) of the First Schedule of the Customs Tariff Act, 1975. I concurred with the view expressed by the department in terms of amended provision of law.

9. On the basis of foregoing discussions and findings, I am of the view that the product i.e. Interactive Flat Panel merit classification under CTH 8528 (Monitors and projectors not incorporating television reception apparatus; television reception apparatus, whether or not incorporating radio broadcast receivers or sound or video recording or reproducing apparatus), more specifically under CTI 85285900 (Other) of the First Schedule of the Customs Tariff Act, 1975, in terms of the changes made in the Budget, 2025 and subsequent Circular No. 12/2025-Customs dated 7th April 2025.

10. I rule accordingly.

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

F. No. CAAR/CUS/APPL/5/2025-O/o Commr-CAAR-Mumbai                     Dated: 21-04-2025

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

1. M/s. Netiink ICT Private Limited,
X/24 A&B, CRT Building,
Jupiter Junction, Piravom Road,
Oliyappuram P.O.,Koothattukulam, ErnakuIam-686 662.
Email: import@netlinkict.com

2. The Commissioner of Customs, Import
Chennai-II (Import), Customs House,
60, Rajaji Salai, Chennai- 600001
Email: commr2-cuschn@gov.in

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

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

5. The Commissioner (Legal), CBIC 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, Ne> Delhi-110001.
Email: m em .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