2025(05)LCX0427(AAR)

Orpak Systems India Private Limited

decided on 30-05-2025

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. Orpak Systems India Private Limited (IEC No.: 3109018837) (hereinafter referred to as 'the Applicant’) filed an application (CA AR-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 16.01.2025 along with its enclosures in terms of Section 28H(1) of the Customs Act, 1962(hereinafter referred to as the ' Act also’). The Applicant is seeking advance ruling on the issue of classification of “Indicator Panel Incorporating Liquid-Crystal Display (LCD) Screen, Decoder Integrated Circuit (IC), and Processor IC (Parts of fuel pump)”, under CTH 8531 as indicator panel, or under CTH 8524 as Flat Panel Display modules, of the First Schedule of the Customs Tariff Act, 1975, or otherwise.

2. Submission by the Applicant:

2.1 M/s Orpak Systems India Private Limited (hereinafter referred to as the "Applicant") is a fully owned subsidiary of M/s Orpak Systems Ltd, Israel. The Company has its registered office at SF No 627/2628/2, Sector W-4, PDP, Coimbatore Campus, Eachanari, Chettipalayam Road, INDL Estate Post, Malumichampatti, Coimbatore Industrial Estate, Coimbatore South, Coimbatore6410213 Tamil Nadu, India. The Company is engaged in business of supply fuel dispenser, next-generation solutions for fuel retail and fleet management business.

2.2 Since the Quarter 4 of FY 2024-25, amongst other products, the Company is planning to import indicator panel incorporating Liquid-crystal display (LCD) screen, Decoder Integrated circuit ( IC) & Processor IC having Model No as follows:

Table

(Hereinafter referred to as 'Goods’/ ’Product under consideration') from China in completely built unit (CBU) form for sale in India.

Product usage, functions and other technical capabilities

2.3 The product under consideration is an indicator panel incorporating Liquid-crystal display (LCD) screen, Decoder Integrated circuit (IC) & Processor IC. They are used with the fuel dispensing system to indicate the volume & price of the fuel dispensed through the fuel pump. The image of the product under consideration is reproduced below for your reference:

2.4 The product is an indicator panel, which is essential components of fuel dispensers, designed to provide visual information to consumers regarding the volume and price of fuel being dispensed. They serve as a crucial interface between the dispenser and the user, ensuring transparency and accuracy in fuel transactions.

2.5 The key components of the indicator panel and their respective functions are enumerated below for ease of understanding:

➣ Liquid-Crystal Display (LCD) Screen:

• A flat panel display that uses liquid crystals to produce images.

• Displays the volume and price of fuel being dispensed in clear, legible characters.

• May include additional information such as the grade of fuel & total cost.

• Further, it is highlighted that these are segmented LCD's (i.e., LCD that consists of individual segments that can be turned on or off to form numbers and symbols.).

• Used to display the volume and price of fuel being dispensed.

➣ Decoder & Processor Integrated Circuit (IC):

• Processes signals from the fuel pump and other components of the dispenser.

• Decodes and interprets data related to fuel flow rate, volume, and price.

• Transmits the decoded information to the LCD screen for display.

• A powerful microprocessor that controls the overall operation of the indicator panel.

• Handles calculations, data processing, and communication with other components of the dispenser.

• Ensures accurate and timely display of information.

➣ Aluminium Panel:

• A sturdy metal panel that houses the integrated circuits and LCD screen.

• Provides a protective enclosure and a mounting surface for the display.

➣ Backlight:

• An illumination source that provides background lighting for the LCD screen.

• Enhances visibility in low- light conditions.

The block design of a typical indicator panel is as below for reference:

2.6 These indicator panels can be tailored to display 4-6 digit as per the specific needs. This includes options for changing the size, display content, etc. They may also incorporate backlighting, touchscreen functionality etc. depending upon the need of the customer. The primary application for this kind of display is in fuel dispensers, where it provides essential information to consumers regarding fuel volume and price. This display screens offer a versatile and reliable solution for displaying numerical information in fuel dispensers and can also be used in various industrial applications that require clear and reliable numerical displays, such as vending machines, digital clocks, and laboratory equipment.

3. Applicants interpretation of Law/Facts:

Classification of the product under under CTH 8524.

3.1 The applicant submitted that the product under consideration comprises of LCD module amongst other drivers and control gear for incorporating the same with fuel dispenser pump. Therefore, a view can be taken that the product under classification is largely comprising of LCD display as enumerated in the pictures above, and thus classifiable under CTH 8524. For ease of reference, the relevant extract of the Schedule 1 to the Customs Tariff Act, 1975 has been provided below:

Table 2

3.2 in terms of Chapter Note 7 to Chapter 85, 'flat panel display modules’ are defined as devices or apparatus designed for information display, equipped with at least a display screen, and intended for integration into articles of other headings prior to use. These display screens can exhibit various forms, including flat, curved, flexible, foldable, or stretchable. Further, it is submitted that flat panel display modules may incorporate additional elements, such as those required for receiving and distributing video signals to pixels.

3.3 However, heading 8524 does not encompass display modules equipped with components for converting video signals (e.g., scaler ICs, decoder ICs, or application processors), as well as module that have "otherwise acquired the characteristics of goods under other headings".

3.4 Further, it is highlighted that for the classification of flat panel display modules as defined in chapter note 7, heading 8524 shall take precedence over any other heading within Harmonized System Nomenclature.

3.5 On plain reading of the above-mentioned chapter notes, it is clear that the heading 8524 covers the following type of flat panel display:

• Flat, curved, flexible, foldable, or stretchable display screen;

• Flat panel display designed to be incorporated into other products before final use;

• Flat panel display including additional components such as video signal receiver, pixel signal converter for displaying on screen etc., just beyond the display screen.

3.6 However, in terms of chapter note 7, CTH 8524 specifically excludes flat panel display modules with equipped with advanced components for converting video signals (e.g., scaler IC, decoder IC, application processor) or that have the characteristics of products in other headings. Therefore, it is pertinent to highlight that CTH 8524, doesn’t include flat panel display modules which are equipped with components for converting video signal such as scaler IC, decoder IC, processor IC.

3.7 Basis the above submission, it can be concluded that the product under consideration would be outside the purview of CTH 8524 only if it contains a processor IC and a decoder IC that perform a critical function in converting video signals within the flat panel display. As enumerated in para 3-6 of Annexure A, in the case of product under consideration, it is clear that the flat panel display incorporates decoder IC as well as processor which undertake the conversion of video signals. The detailed process of signal conversion is outlined below:

• Receives signals: The decoder IC receives input signals, which could be digital or analog, from the fuel dispensing pump’s control system.

• Converts signals: The Decoder IC processes these input signals and converts them into a format suitable for the LCD panel. This involves tasks like decoding video data, adjusting color, and synchronizing the signal with the panel's refresh rate.

• Transmits signals: The converted signals are then transmitted to the processor IC.

• The Processor IC acts as the brain of the LCD panel, controlling various functions such as:

✔Displaying the desired content (numbers in this case) on the LCD display panel;

✔Adjusting brightness, contrast, and color settings;

✔Handling interactions with other components (e.g., touchscreens, buttons).

3.8 The Processor IC and Decoder IC work together to convert raw data (such as sales volume and price) into a visually understandable format. The LCD panel then displays this information, allowing users to easily monitor the fuel dispensing process. Therefore, it is evident that both the Processor IC and Decoder IC are integral components in the functioning of LCD flat display panel used in fuel dispensing pumps, enabling the accurate and efficient display of essential information.

3.9 Basis the above submissions, it is evident that as the product in question contains integrated decoder iC and processor IC components that are specifically used for converting and processing video signals received from the fuel dispensing control system. In view of the same, it seems that the product consideration would be excluded from the scope of CTH 8524.

3.10 This contention also finds support from the WCO Explanatory Notes of tariff heading 8524, which specify that this heading encompasses flat panel display modules, defined as electronic devices designed to present visual information, consisting of the following components:

• Flat panel display modules without drivers or control circuits, which are generally referred to as 'cells';

• Flat panel display modules with drivers or control circuits (i.e., Drivers or control units are added to 'cells’). These driver & control circuit is added to cells to control individual pixels receive video signals and display them on the screen. Such displays may incorporate backlight units (for LCDs) or frames; and

• Flat panel display modules with touch-sensitive screens.

3.11 in the instant case, the product under consideration consists of segmented LCDs. A segmented display is a device comprising multiple independent segments arranged in such a way that the device can represent letters and/or numerals by selectively activating, i.e., turning on, specific segments of the display. These segments may be activated electrically (e.g., illuminated) or mechanically (e.g., uncovered). Reference is made to the patent information provided by the European Patent Office, accessible via the following link https://patents.google.com/patent/EPI !83674A I /en.

3.12 It is submitted that a non-segmented display is made up of a grid of individual pixels which are capable of displaying more complex information such as higher resolution detailed images, videos, and various fonts or characters. In summary it can be said that Segmented panels are simple and ideal for basic numeric or alphanumeric displays, while non-segmented panels offer much more flexibility, allowing for detailed graphics and varied information.

3.13 As outlined above, in terms of the WCO explanatory notes to CTH 8524, this heading includes flat panel display modules with drivers or control circuits integrated into the cells, allowing for the control of individual pixels and the display of complex images and videos. Therefore, the flat panel displays covered under CTH 8524 can be classified as non-segmented display panels, which are capable of presenting high-resolution images and videos and controlling individual pixels.

3.14 Basis the above submission, the company submits that since the imported goods in the present case are made up of segmented LCD's, therefore, the same would not get covered under CTH 8524 which pertains to non-segmented displays.

3.15 It is further submitted that as per Rule 1 of the General Rules for the interpretation of the Harmonized System, 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 and, provided such headings or Notes do not otherwise require, according to the provision stipulated therein. Therefore, by application of the chapter note 7 to Chapter 85, it can be concluded that the product under consideration is outside the purview of CTH 8524.

Classification of the product under CTH 8531.

3.16 The company humbly submits that the product under consideration, viz. "indicator panels incorporating LCD module" are essentially visual signaling apparatus. Heading 8531 covers "Electric sound or visual signaling apparatus". It is undisputed that the subject goods are intended for use for display of volume & price of the fuel, which means that it is intended to visually signal volume, price, etc. of the fuel dispensing. Accordingly, the categorization of the subject goods as "signaling apparatus" can't be faulted with. For ease of reference, the relevant extract of the Schedule 1 to the Customs Tariff Act, 1975 has been provided below.

Table 3

3.17 In terms of WCO explanatory notes to CTH 8531 are fairly descriptive and restricted as to the type of "signaling" indicator panels and the like must perform in order to be classified under the heading. The EN 85.31 provides, in part: "these are used (e.g., in offices, hotels and factories) for calling personnel, indicating where a certain person or service is required, indicating whether a room is free or not. It includes:

"This heading includes, inter alia:

(D) Indicator panels and the like. These are used (e.g., in offices, hotels and factories) for calling personnel, indicating where a certain person or service is required, indicating whether a room is free or not. They include:

• Room indicators. These are large panels with numbers corresponding to a number of rooms.

• Number indicators. The signals appear as illuminated figures on the face of a small box; in some apparatus of this kind the calling mechanism is operated by the dial of a telephone. Also clock type indicators in which the numbers are indicated by a hand moving round a dial.

• Office indicators, for example, those used to indicate whether the occupant of a particular office is free or not.

• Lift indicators. These indicate, on an illuminated board, where the lift is and whether it is going up or down. etc."

... (Emphasis supplied)

3.18 From the emphasized portion of the above extracts, it appears that only those LCDs which are limited by design and/or principal use to "signaling" are classifiable in heading 8531. The sole contention for the subject goods to be classified as an indicator panel incorporating LCDs under heading 8531, "the article must belong to the class or kind of merchandise that is principally used to display limited information that is easily understood by the person viewing it".

3.19 The company submits that the subject goods are more specifically described under heading 8531. In the instant case the subject goods are similarly operationally limited to performing signaling functions. They contain permanently segmented LCD displays, which is capable to displaying limited information of the type a user would easily understand, e.g., volume of the fuel, the price of the fuel, quantity of fuel dispensed etc. Moreover, these displays include the drive circuitry, decoder IC & processor necessary to illuminate a particular segment in the LCD based on signals transmitted from the processor IC. The functions performed by these modules are akin to those performed by the products listed as exemplars in the WCO explanatory notes s to heading 8531.

3.20 It is also submitted that the principal uses enumerated above are applications in which only certain limited indication information is provided to a user (such as measurement, coordinates, flow rate, etc.), and as such, the subject goods (i.e., indicator panels incorporating LCDs) provide similar information as those types of limited indication functions enumerated in the WCO explanatory notes above. Therefore, the company is of the view that the subject goods (i.e., indicator panels) are correctly classified in heading 8531, as visual signaling apparatus. Further, tariff entry 8531 20 00 is a direct entry for indicator panels incorporating LCD, therefore, the product under considerations would be more appropriately classified under 8531 20 00 at eight-digit level.

3.21 It is further submitted that in term of Rule 1 of General Rules of Interpretation of the Harmonized System (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 and, provided such headings or Notes do not otherwise require, according to the provision stipulated therein.

3.22 Further, GRI Rule 3(a) states that the heading which provides the most specific description shall be preferred to headings providing a more general description. As stated above, it is undisputed that the subject goods are intended for use for display of volume & price of the fuel. Given that heading 8531 specifically encompasses "Electric sound or visual signaling apparatus," its application is most appropriate for categorizing the subject goods as "signaling apparatus" in accordance with GRI Rule 3(a).

3.23 In this regards reliance is placed on judgment of the Hon'ble Tribunal in the matter of M/s Diamond Electricals Ltd. Vs Commissioner of Customs, Chennai, 2012 (280) E.L.T. 137 (Tri. Chennai), wherein it was held that indicating panels with 4 zones incorporating LCD panel, CTEC indicating panel with LCD 1 Loop Apollo Protocol (Non-expandable) and Indicating Panel with LCD Repeater are classifiable under CTH 8531 20 00 of customs tariff act, 1975 as "Indicator panels incorporating liquid crystal devices or light emitting diodes (LED)".

3.24 Recognizing that Customs Tariff are aligned globally at the four-digit levels, it may be useful to refer to international classification practice. In this regard, acknowledging that these have only persuasive value, reliance is placed on the United States Customs and Border Protection ('US CBP') ruling number HQ H026661 dated 08.07.2008, wherein the customs authorities have held that graphical LCD displays which are interfaces for automotive, industrial and marine equipment applications are classifiable under heading 8531 which provides for "electric sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530: indicator panels incorporating liquid crystal devices (LCD's) or light emitting diodes (LED's)".

3.25 Further, reliance is also placed on US CBP in ruling HQ H049555 dated 13.04.2009, wherein similar kind of product i.e., LDC modules for displaying character and is used in automobiles was classified under tariff heading 8531. The LCD modules in this case contain drive circuitry capable of illuminating segments, characters or icons, but required an external microprocessor to instruct the drive circuitry to turn on or off. It contained approximately 25 segment-style characters, most of which display a full range of numbers and letters, and 50 permanently etched icons. The display measures approximately 7 inches in length, 2.5 inches in height, and 1 mm in thickness.

3.26 It is also submitted that in Ruling No. N306705 dated 31.10.2019, it was held that LCD indicator panels from China, used within auto mobiles that has an LCD display that uses 6 segment style characters and 24 etched icons to relay information & 15 segment-style characters and 19 etched icons to relay information under the tariff heading 8531. These LCD display modules are used in vehicle dashboards or HVAC system panels. They indicate the amount of fuel remaining in the tank, driving distance, time, audio output, external temperature and RPM by lighting pre­designed letters, numbers, symbols and shapes in segmented formats.

3.27 Without prejudice to the submissions made above, it is submitted that the product under consideration is not categorically covered under tariff heading 8524 and are correctly classifiable under tariff heading 8531.

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. Indicator Panel Incorporating Liquid-Crystal Display (LCD) Screen, Decoder Integrated Circuit (IC) & Processor IC at the jurisdiction of Office of the Commissioner of Customs, Air Cargo Complex, Chennai. The application was forwarded to the Office of the Commissioner of Customs, Air Cargo Complex, Chennai for their comments on 21.01.2025.

The concerned jurisdictional Commissionerate vide their letter dated 17.03.2025 has submitted as follows:

➣ As per Chapter Note 7 to Chapter 85, it is evident that flat panel display modules which are equipped with components for converting video signals (e.g., a scaler IC, Decoder IC or application processer IC) are excluded from the heading 8524. Thus, the CTI 85249190 submitted by the importer as one of the contending CTI which as per many industry participants is considered as proper classification is incorrect and cannot be considered

➣ As per Explanatory notes the CTI 85312000 "Indicator Panels Incorporating Liquid Crystal Devices (LCD) or Light Emitting Diodes (LED)" covers panels which are used (e.g., in offices, hotels and factories) for calling personnel, indicating where a certain person or service is required, indicating whether a room is free or not. They include:

a. Room Indicators: These are large panels with numbers corresponding to a number of rooms. When a button is pressed in the room concerned the corresponding number is either lit up or exposed by the falling away of a shutter or flap.

b. Number Indicator: The signals appear as illuminated figures on the face of a small box; in some apparatus of this kind the calling mechanism is operated by the dial of the telephone. Also clock type indicators in which the numbers are indicated by a hand moving round a dial.

c. Office Indicators, for example, those used to indicate whether the occupant of a particular office is free or not. some types are merely a simple "come in" or "engaged" sign illuminated at will by the occupant of the office.

d. Lift Indicators. These indicate, on an illuminated board, where the lift is and whether it is going up or down.

e. Engine room telegraph apparatus for ships.

f. Station indicating panels for showing the times and platforms of trains.

g. Indicators for race courses, football stadiums, bowling alleys, etc.,

Certain of these indicator panels, etc., also incorporate bells or other sound signaling devices.

Further, static signs, even if lit electrically (e.g., lamps, lanterns, illuminated panels, etc.) are not regarded as signaling apparatus. They are therefore not covered by this heading but are classified in their own appropriate headings (heading 83.10, 9405, etc.).

➣ The scope of Indicator Panels Incorporating Liquid Crystal Devices (LCD) or Light Emitting Diodes (LED)" falling in CTI 85312000 has been clearly defined as to 'calling personnel, indicating where a certain person or service is required, indicating whether a room is free or not' whereas the item under consideration are meant to display the signals processed by the microprocessor received from the fuel pump and other components of the dispenser, which are further decoded and displayed as the data related to fuel flow rate, volume and price etc., it is clear that the subject goods do not fall in any of the categories mentioned in the explanatory notes above and therefore they would not be covered under CTI 85312000. Thus, the contentions of the importer that the import goods merits classification under CTI 85312000 also appear incorrect.

➣ Further, as the import goods are LCD modules equipped with a decoder IC and a Processor IC with permanently fixed back light, which displays the data from a particular machine (which in the present case is a fuel dispenser) shall be in terms of the Note 2(b) of Section XVI of the Customs Tariff Schedule II, would merit classification as parts of that machine.

➣ To identify the correct classification of the import goods which are parts of a fuel dispenser it needs to see where a fuel dispenser would merit classification. In this regard, it pertinent to note that CTH 8413 covers pumps for liquids, whether or not fitted with a measuring device; liquid elevators.

➣ As per the Explanatory notes of CTH 8413 heading covers most machine and appliances for raising or otherwise continuously displacing volumes ofliquids (including molten metal and wet concrete), whether they are operated by hand or by any kind of power unit, integral or otherwise.

➣ The heading also includes delivery pumps equipped with measuring or price-calculating mechanisms such as are used for supplying petrol or oil in garages, and also pumps specially designed for use with other machines, vehicles, etc., (including petrol, oil or water pumps for internal combustion engines, and pumps for man-made textile fiber spinning machines).

➣ The CTI 84131191 cover the pumps fitted or designed to be fitted with a measuring device for dispensing fuel or lubricants, of the type used in filling stations or in garages for dispensing fuel. The indicator panel fitted with this machine and proposed to be imported would be liable to be classified as parts under CTH 8413 and more appropriately under CTI 84139190.

5. Details of Hearing

5.1 A hearing was conducted on 08.04.2025 at 11.30 AM. Sh. Animesh Mohanti and Sh. Parth Shah, Authorized Representatives on behalf of the applicant, appeared online for the hearing and reiterated the contentions submitted in the application. They submitted that subject goods i.e., Indicator Panel Incorporating Liquid-Crystal Display (LCD) Screen, Decoder Integrated Circuit (IC) & Processor IC intended in use of fuel pumps to display the volume and price of the fuel dispensed merit classification under CTI 85312000 under visually signaling apparatus/indicator panel. They suggested that an alternate classification can be under CTH 8524 but the CTH 8531 is most appropriate.

Nobody appeared on behalf of the department for the hearing.

Additional Submission

6.1 The applicant vide their letter dated 16.04.2025 made following additional submissions:

➣ In terms of Explanatory Notes for Tariff Heading 8413, this heading covers most machines and appliances for raising or otherwise continuously displacing volumes ofliquids, whether they are operated by hand or by any kind of power unit, integral or otherwise.

➣ The Tariff Entry 8413.9 LOO of the Customs Tariff covers part of wide range of pumps that are used to deliver liquids. HSN Explanatory Notes to this heading indicate that it covers a broad range of pumps with built-in or designed-to-be-integrated volumetric control mechanisms. These pumps can also perform various additional functions. It is also highlighted in the explanatory notes that if the measuring device is separate, both the pump and device should be classified separately. This heading also applies to pumps for fuel delivery, food processing, and other industries.

➣ One can submit, for the sake of argument, though not admitted, that the indicator panel incorporating LCD display, decoder IC & processor IC can be considered as an integral 'part' of fuel dispensing pumps. As such, these components are intended for exclusive and principal use with fuel dispensing pumps. Hence the appropriate classification for the subject goods should be under tariff entry 8413 91 90 (i.e., Part: Other category).

➣ However, in this regard, applicant would like to invite attention to the term of the Explanatory Notes to tariff heading 8413, parts specifically designed for use with pumps, such as pump housings or bodies, and connecting rods designed to drive the piston in pumps etc., are also classified under this heading subject to Note 2 outlined in the General Explanatory Note to Section XVI.

➣ It is the applicant's submission that General Explanatory Note 2 to Section XVI sets an exclusive condition for any item to fall within the purview of the expression "parts".

➣ In accordance with Note 2(a) to Section XVI, the classification of the product under consideration as 'parts' would be contingent upon their inability to be classified under any other heading within Chapters 84 or 85. However, given the direct tariff reference of the product under consideration under CTH 8531 for indicator panels, the applicant maintains that the product in question cannot be classified as a 'part' of fuel dispensing pumps under CTH 8413 by virtue of note 2(a) to Section XVI.

➣ Reliance is placed on Order-in-Original No. 112814/2025 dated 06.02.2025 issued by the Additional Commissioner, Customs Import Chennai, in the case of M/s Gilbarco Veeder Root India Pvt. Ltd., wherein it was held that indicator panels incorporating LCD, decoder IC, and processor IC used in fuel dispensing pumps are classifiable under tariff entry 8531 20 00. The adjudicating authority noted that these panels merely display values and do not affect the fuel pump's dispensing function, as evidenced by the existence of pumps functioning without such panels.

6.2 This office, vide email dated 29.04.2025, informed the applicant that, based on publicly available information, the product described appears to be commonly referred to in the market as a fuel dispenser display board/display screen. Nowhere has the product been found to be described as an "indicator panel," as claimed by the applicant. It is observed that the term "indicator panel" is not commonly used for such products. Accordingly, the applicant was requested to clarify the basis for referring to the product as an "indicator panel."

Additionally, the applicant was asked to specify how the supplier describes the goods and under what name the goods are marketed or listed on the manufacturer's website. Further, it was noted that the product may incorporate touchscreen functionality, and the applicant was requested to clarify the intended use of the touch-screen functionality in the product, if any, and to confirm whether the product incorporates any input features—such as buttons or similar mechanisms—that allow the user to provide specific inputs.

In response, vide email dated 22.05.2025, the applicant has submitted that the supplier describes the product as a fuel dispenser display board/display screen. It has been clarified that the product does not incorporate any touchscreen functionality. The applicant has further stated that the product under consideration does not have any input features—such as buttons, touchpads, or similar mechanisms—integrated within the LCD unit. The LCD is solely designed for display purposes and does not enable any form of user interaction or data entry. Any required user input is facilitated exclusively through an external keypad unit, which is separate from the LCD module. As such, the LCD does not support or allow input through touch, buttons, or any other interactive interface. Users are not able to transmit or enter information through the LCD in any manner.

DISCUSSION AND FINDINGS

7.1 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, comments received from the concerned jurisdictional Commissionerate and additional submission made by the applicant. Therefore, I proceed to pronounce a ruling on the basis of information available on record as well as existing legal framework.

7.2 The Applicant has sought advance ruling in respect of the following question:

a. Whether the product i.e., "Indicator Panel Incorporating Liquid-Crystal Display (LCD) Screen, Decoder Integrated Circuit (IC), and Processor IC", under CTH 8531 as indicator panel, or under CTH 8524 as Flat Panel Display modules, of the First Schedule of the Customs Tariff Act, 1975, or otherwise.

7.3 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.

7.4 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.

7.5 The applicant submitted that the product under consideration is an indicator panel comprising a Liquid Crystal Display (LCD) screen, Decoder Integrated Circuit (IC), and Processor IC, designed for use in fuel dispensing systems to display the volume and price of fuel dispensed. This indicator panel is a critical component of the dispenser, serving as a user interface that ensures transparency and accuracy in fuel transactions. The segmented LCD screen presents clear, legible information such as volume, price, fuel grade, and total cost. The decoder and processor ICs receive and process data from the fuel pump, decode fuel flow, volume, and price information, and transmit it to the LCD for display. A powerful microprocessor manages, the panel's Operations, including data processing and communication with other dispenser components. The aluminium panel provides structural support and protection for the electronic components, while the integrated backlight enhances screen visibility in low-light conditions, ensuring effective operation in all environments.

7.6 Before proceeding with the classification of these devices, it is essential to understand the nature of the subject goods, which have been described by the applicant as an Indicator Panel incorporating a Liquid Crystal Display (LCD) screen, Decoder Integrated Circuit (IC), and Processor IC. These panels are used in fuel dispensing pumps to display the volume and price of fuel dispensed, and they serve as a critical component of the fuel dispenser system.

Based on publicly available information, the product described appears to be commonly referred to in the market as a fuel dispenser display board or display screen. There is no reference to the product being described as an "indicator panel," as claimed by the applicant. It is observed that the term "indicator panel" is not typically used for such products in commercial or technical contexts. Accordingly, the applicant was requested, vide email dated 29.04.2025, to clarify the basis for referring to the product as an "indicator panel." In response, vide email dated 22.05.2025, the applicant submitted that the supplier describes the product as a fuel dispenser display board/display screen. Therefore, it is evident that the goods described by the applicant as an "indicator panel" are, in fact, fuel dispenser display boards/display screens.

According to the information available on the website of Mouser Electronics https://www.mouser.in/c/embedded-solutions/display-modules/#, Display modules are electronic components or devices that provide visual output by displaying text, images, or graphical content. They typically consist of an integrated display panel, backlighting, and control circuitry. Display modules come in various types such as LCD (liquid crystal display), OLED (organic light-emitting diode), TFT (thin-film transistor), or e-ink displays. These modules are widely used in consumer electronics, industrial systems, medical devices, and other applications where visual information presentation is crucial. They offer a means to convey information, enhance user interfaces, and provide visual feedback in a wide range of electronic devices and systems.

Similarly, as per the website of Techdelivers <https://techdelivers.com/Display-Modules?srsltid=AfmBOoqnLD925q9FBrghwTCfGaedO4iJtle09GapBTNniVneVzmWuGL0A>, display module or a display driver, is an electronic component that is used to provide visual output in electronic devices. It typically consists of a display panel, a driver circuit, and sometimes additional components like backlighting or touch sensors. Display modules come in various forms and technologies, each with its own characteristics and applications.

Thus, based on publicly available information, it is evident that a typical display module consists of a display panel, integrated circuits, a backlight unit, and sometimes a touch sensor. Considering the technical details and submissions related to the subject goods, it is observed that the product under question i.e.. Fuel dispenser display boards/display screens (described as an Indicator Panel incorporating an LCD screen. Decoder IC. and Processor IC) qualifies as a display module for fuel pump. It is specifically used to visually communicate real-time transaction data to both the customer and operator during the fuelling process, including the volume of fuel dispensed, price per unit, total cost, and in some cases, the fuel grade. Thus, the product in question is a part of the fuel dispenser pump which is further confirmed by the applicant vide their email dated 22.05.2025.

7.7 I note that the Customs Tariff Heading (CTH) 8413 covers "Pumps for liquids, whether or not fitted with a measuring device; liquid elevators". The relevant Customs Tariff entries to Heading 8413 is reproduced below for ease of reference:

From the above, I find that the Chapter Heading 8413 11 of the Customs Tariff covers "Pumps for dispensing fuel or lubricants, of the type used in filling stations or in garages". The applicant has also submitted that the Fuel dispenser display boards/display screens (Indicator Panel incorporating a Liquid Crystal Display (LCD) screen, Decoder Integrated Circuit (IC), and Processor IC as described by the applicant) is used in fuel dispensing pumps to indicate the volume and price of the fuel dispensed and it is an essential component of fuel pump. Thus, the fuel pump can be said to be a type of pump which are used for dispensing fuel and therefore classifiable under CTI 84131191 of the Customs Tariff.

It could be seen from above that the Heading 8413 primarily deals with Pumps for liquids, whether or not fitted with a measuring device; liquid elevators and parts thereof. The heading is divided into nine major sub-headings namely (a) Pumps fitted or designed to be fitted with a measuring device (b) Hand pumps, other than those of sub-heading 8413 11 or 8413 19 (c) Fuel, lubricating or cooling medium pumps for internal combustion piston engines (d) Concrete pumps (e) Other reciprocating positive displacement pumps (f) Other rotary positive displacement pumps (g) Other centrifugal pumps (h) Other pumps-liquid elevators and (i) parts. Thus, it is pertinent to mentioned that Chapter Heading 8413 also covers "parts of the pump for dispensing fuel". There could be no dispute in the present case that the items in question is directly usable and identifiable as parts of the pump for dispensing fuel.

7.8 It is seen that HSN Explanatory Notes to headings 8413 as regards parts falling thereon, stipulates that classification of parts of machines of heading 8413 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 Customs 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 1 to Chapter 84 and Note 1 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 be 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"

7.9 I find that the product under question namely Fuel dispenser display boards/display screens (Indicator Panel as described by the applicant) is a display module comprising a Liquid Crystal Display (LCD) screen, Decoder Integrated Circuit (IC), and Processor IC for fuel pump. At first glance, it may appear that the product could be classifiable under Chapter Heading (CTH) 8524, which covers "Flat Panel Display Modules, whether or not incorporating touch-sensitive screens." Therefore, it becomes essential to examine whether the product in question appropriately falls under Heading 8524, or is more suitably classified elsewhere.

In this regard, Chapter Note 7 to Chapter 85 is relevant. It provides the following clarification:

"7. For the purposes of heading 8524, -flat panel display module refer to devices or apparatus for the display of information, equipped at a minimum with a display screen, which are designed to be incorporated into articles of other headings prior to use. Display screens for flat panel display modules include, but are not limited to, those which are flat, curved, flexible, foldable or stretchable in form. Flat panel display module may incorporate additional elements, including those necessary for receiving video signals and the allocation of those signals to pixels on the display. However, heading 8524 does not include display modules which are equipped with components for converting video signals (e.g., a scaler IC, decoder IC or application processor) or have otherwise assumed the character of goods of other headings.

For the classification of flat panel display modules defined in this Note, heading 8524 shall take precedence over any other heading in the Nomenclature".

A plain reading of the above note makes it clear that Heading 8524 expressly excludes display modules that are equipped with components for converting video signals, such as a scaler IC, decoder IC, or application processor. Additionally, it excludes those modules that have assumed the character of goods of other headings.

In the present case, the applicant has submitted that the product in question contains both a decoder IC and a processor IC, which work in conjunction to convert raw data (e.g., fuel volume and price) into a visually understandable display format. This functional aspect indicates that the module performs video signal processing and data conversion, and is not limited to merely receiving and displaying information.

In light of these facts, it is evident that the product is excluded from the scope of Heading 8524. The presence of components such as the decoder IC and processor IC confers upon the product a character beyond that of a simple flat panel display module, as contemplated under Chapter Note 7. Accordingly, the product cannot be classified under Heading 8524.

7.10 The applicant has submitted that the product under consideration, namely, Fuel dispenser display boards/display screens (indicator panel as described by the applicant), is intended for use in displaying the volume and price of fuel. This indicates that the product functions as a visual signaling apparatus, designed to convey key information such as volume and price to the user in a clear and visible format. Based on this functional use, the applicant has proposed that the product is classifiable under Customs Tariff Item (CTI) 8531 20 00, which covers "Indicator panels incorporating liquid crystal devices (LCD) or light-emitting diodes (LED).''' Accordingly, it is now necessary to examine the appropriateness of classifying the subject goods under CTI 8531 20 00, as proposed by the applicant.

I note that the Customs Tariff Heading (CTH) 8531 covers "Electric sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530". The relevant HSN Explanatory Notes to Heading 8531 is reproduced below for ease of reference:

"85.31 - Electric sound or visual signalling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 85.12 or 85.30. 8531.10 - Burglar or fire alarms and similar apparatus
8531.20 -Indicator panels incorporating liquid crystal devices (LCD) or light-emitting diodes (LED)
8531.80 -Other apparatus 8531.90-Parts

With the exception of signalling apparatus used on cycles or motor vehicles (heading 85.12) and that for traffic control on roads, railways, etc. (heading 85.30), this heading covers all electrical apparatus used for signalling purposes, whether using sound for the transmission of the signal (bells, buzzers, hooters, etc.) or using visual indication (lamps, flaps, illuminated numbers, etc.), and whether operated by hand (e.g., door bells) or automatically (e.g., burglar alarms).

Static signs, even if lit electrically (e.g., lamps, lanterns, illuminated panels, etc.) are not regarded as signalling apparatus. They are therefore not covered by this heading but are classified in their own appropriate headings (headings 83.10, 94.05, etc.).

The heading includes, inter alia:

(A) Electric bells, buzzers, door chimes, etc. The bells consist essentially of an electro-magnetically operated appliance which causes a small hammer to vibrate and strike a bell dome. Buzzers are similar but without the bell dome. Both are used very extensively for domestic purposes (e.g., as door bells), and in offices, hotels, etc. The heading also covers electric door chimes in which one or more metal tubes are struck, emitting a musical note or series of musical notes, and electrically operated church bells, other than carillons suitable for playing music (Chapter 92).

Electric bells and door chimes are usually designed to be operated from a low tension supply (primary cell or battery), but in certain cases they incorporate a transformer to step down the mains voltage.

(B) Electric sound signalling apparatus, horns, sirens, etc. The sound is produced by a vibrating reed, by a rotating disc set in motion electrically or electronic sound generator, they include factory sirens, air raid sirens, ships sirens, etc.

(C) Other electrical signalling apparatus (winking or intermittent lights, etc.) for aircraft, ships, trains or other vehicles (other than for cycles or motor vehicles heading 85.12), but not radio or radar apparatus of heading 85.26.

(D) Indicator panels and the like. These are used (e.g., in offices, hotels and factories) for calling personnel, indicating where a certain person or service is required, indicating whether a room is free or not. They include:

(1) Room indicators. These are large panels with numbers corresponding to a number of rooms. When a button is pressed in the room concerned the corresponding number is either lit up or exposed by the falling away of a shutter or flap.

(2) Number indicators. The signals appear as illuminated figures on the face of a small box; in some apparatus of this kind the calling mechanism is operated by the dial of a telephone. Also clock type indicators in which the numbers are indicated by a hand moving round a dial.

(3) Office indicators, for example, those used to indicate whether the occupant of a particular office is free or not. Some types are merely a simple "come in" or "engaged" sign illuminated at will by the occupant of the office.

(4) Lift indicators. These indicate, on an illuminated board, where the lift is and whether it is going up or down.

(5) Engine room telegraph apparatus for ships.

(6) Station indicating panels for showing the times and platforms of trains.

(7) Indicators for race courses, football stadiums, bowling alleys, etc.

Certain of these indicator panels, etc., also incorporate bells or other sound signalling devices.

The heading does not cover public maps of roads or railways in which a particular place, road, section or route is illuminated on pressing an appropriate button, nor electric advertising signs.

(E) Burglar alarms. These consist of two parts: a detecting part, and a signalling part (bell, buzzer, visual indicator, etc.) which is set off automatically when the detecting part operates. Burglar alarms operate by various means, e.g.:

(1) By electrical contacts which are operated by stepping on a certain part of the floor, opening a door, breaking or touching fine wires, etc.

(2) By capacitance effects. These are used often in connection with safes; the safe acts as one plate of a capacitor whose capacitance is affected by the approach of any body, thus upsetting the electrical circuit and setting off the alarm.

(3) Photoelectric devices. A ray (often of infra-red light) is focussed on a photoelectric cell; when the ray is interrupted, the change in current in the photoelectric cell circuit sets off the alarm.

(F) Fire alarms. Automatic alarms also consist of two parts: a detecting part, and a signalling part (bell, buzzer, visual indicator, etc.). They include:

(1) Apparatus operated by a fusible product (wax or special alloy) which melts when the temperature rises above a certain point, thus allowing electrical contacts to close and set off the alarm.

(2) Apparatus based on the expansion of a bi-metal strip, liquid or gas expansion beyond a certain point operating the alarm, in one type, the expansion of a gas forces a piston to move in a cylinder; a valve is incorporated so that a slow expansion does not set off the alarm, but only a sudden expansion due to a sudden rise in temperature.

(3) Apparatus based on the variation in the electrical resistance of an element subjected to a change in temperature.

(4) Apparatus based on photoelectric cells. A ray of light is focussed on the cell and, if obscured to a predetermined extent by smoke, operates the alarm. Similar apparatus fitted with a graduated indicator or a recording system fall in Chapter 90.

In addition to the automatic fire alarms, the heading also covers non-automatic alarms, such as are mounted in streets, for calling the fire brigade.

(G) Electric vapour or gas alarms, consisting of a detector and a sound or visual alarm, to warn of the presence of hazardous gaseous mixtures (e.g., natural gas, methane).

(H) Flame alarms (flame detectors) incorporating a photoelectric cell which operates the alarm through a relay when the flame lights or goes out. Detectors not incorporating electric sound or visual alarm devices are classified in heading 85.36".

From the above HSN Explanatory Note to CTH 8531, it is evident that this heading covers all type of electrical apparatus used for signalling purposes, whether using sound for the transmission of the signal (bells, buzzers, hooters, etc. or using visual indication (lamps, flaps, illuminated numbers, etc.), and whether operated by hand (e.g.; door bells) or automatically (e.g., burglar alarms) with the exception of signalling apparatus used on cycles or motor vehicles (heading 85.12).

The applicant contended that the product under question contain segmented LCD displays, which is capable to displaying limited information of the type a user would easily understand, e.g., volume of the fuel, the price of the fuel, quantity of the fuel dispensed etc. and therefore the subject goods are classifiable under the category of indicator panel as mentioned in HSN Explanatory Notes to Heading 8531.

The Explanatory Notes to CTH 8531 further specify that "indicator panels" are used in offices, factories and hotels for calling personnel, indicating where a person or service is required, to indicate whether a room is free or not and include room indicators in hotels, office indicators, lift indicators and indicator panels at station for showing time and platform of the train etc. These are generally standalone devices providing alerts or status information in response to a signal or trigger. In contrast, the subject goods in this case are not standalone apparatus, but rather display modules designed to be integrated into fuel dispensers. These modules are equipped with an LCD screen, decoder IC, and processor IC, which together convert raw operational data (e.g., volume and price of dispensed fuel) into a human-readable visual format. This functionality goes beyond mere signaling, it includes data processing and video signal conversion.

Given this, the subject goods do not fall within the scope of simple visual or sound signaling apparatus contemplated under Heading 8531. The primary function of the product is not to serve as a signaling device, but to operate as a complex display interface forming part of a fuel dispensing system. Therefore, it cannot be classified as an electrical sound or visual signaling apparatus under Heading 8531.

7.10.2 Additionally, based on information from the public domain, the product is consistently referred to as a "fuel dispenser display board" or "display screen," and not as an "indicator panel," as claimed by the applicant. In commercial parlance, the name and intended use of a product play a crucial role in determining its classification. The absence of the term "indicator panel" in trade and marketing references indicates that the product is more accurately identified as a display module designed for integration into a larger machine (i.e., a fuel pump).

Accordingly, as the product is clearly a part of a fuel dispenser rather than an independent signaling apparatus, classification under CTI 8531 20 00 is not appropriate. Further, Rule 3(a) of the General Rules for the Interpretation of the Import Tariff (GRI), which prioritizes classification by the most specific heading, is not applicable here because the product is not known or marketed as an indicator panel and does not meet the criteria set out for goods under Heading 8531.

7.10.3 The applicant has contended that the subject goods serve a similar purpose by displaying limited indication functions enumerated in the WCO Explanatory Notes to CTH 8531. On this basis, the applicant argues that the goods should be classified under Heading 8531 as visual signaling apparatus.

However, the applicant's claim that these modules qualify as "indicator panels or signaling apparatus" under Customs Tariff Item (CTI) 8531 20 00 does not align with the examples provided in the HSN Explanatory Notes. The indicator panels described therein (such as room indicators, office indicators, and lift indicators) are standalone signaling devices designed to provide alerts or status information in response to a signal or trigger. These display modules in question are neither used in the same manner nor perform the same functions as the indicator panels described therein (e.g., room indicators, office indicators, lift indicators). Instead, they function as integrated parts of a fuel dispensing system and are not capable of performing any display or signaling function independently. Their function and application are materially different from those of the visual signaling apparatus contemplated under Heading 8531.

7.10.4 It is pertinent to note that a display module and an indicator panel serve different purposes in electronic and control systems. A display module is a more advanced component designed to present detailed information such as alphanumeric data, graphics, or interactive menus, often using LCD, LED, or OLED screens. It can show real-time values, system messages, or user interfaces and is usually programmable or controlled by a microcontroller. In contrast, an indicator panel is a simpler setup consisting of visual indicators like LEDs or bulbs that display the status of various system functions—such as power, fault, or operational states—using basic on/off signals. While the display module provides comprehensive and dynamic information, the indicator panel offers quick, easily interpreted visual cues for monitoring system conditions. The key differences between a display module and an indicator panel are summarized below:

7.10.5 The applicant in support of their claim had placed reliance on the judgment of the Hon'ble Tribunal in the matter of M/s Diamond Electricals Ltd. Vs Commissioner of Customs, Chennai, 2012 (280) E.L.T. 137 (Tri. Chennai), wherein it was held that indicating panels with 4 zones incorporating LCD panel, CTEC indicating panel with LCD 1 Loop Apollo Protocol (Non-expandable) and Indicating Panel with LCD Repeater are classifiable._nnder CIH.8531 20 00 of customs tariff act, 1975 as "Indicator panels incorporating liquid crystal devices of light emitting diodes (LED)".

In this regard, it is important to note that the product under consideration in the present case, comprising an LCD display, decoder IC, and processor, is a component specifically and undoubtedly designed to be integrated into a fuel dispensing pump. This is materially different from the products examined in the cited judgment, which involved standalone signaling devices. Therefore, the decision in Diamond Electricals Ltd. is not applicable to the present case.

7.10.6 The applicant has placed reliance on US CBP Ruling No. HQ H026661 dated 08.07.2008, wherein graphical LCD displays used as interfaces for automotive, industrial, and marine equipment applications were classified under Heading 8531. Additionally, reference has been made to CBP Ruling No. HQ H049555 dated 13.04.2009, in which LCD modules used for displaying characters in automobiles were also classified under Heading 8531. The applicant has further cited Ruling No. N306705 dated 31.10.2019, where LCD indicator panels imported from China and used in automobiles were classified under the same heading.

In this regard, it is pertinent to note that these rulings were issued by authorities outside India and do not have any binding authority on Indian customs classification. Moreover, the products involved in the cited rulings differ materially from the goods under consideration in the present case. Therefore, the reliance placed on these rulings is not relevant or applicable to the present matter.

7.10.7 The applicant has placed reliance on Order-in-Original No. 112814/2025 dated 06.02.2025, passed by the Additional Commissioner of Customs (Import), Chennai, in the case of M/s Gilbarco Veeder Root India Pvt. Ltd. In the said order, it was held that indicator panels incorporating an LCD, decoder IC, and processor IC used in fuel dispensing pumps are classifiable under tariff entry 8531 20 00. However, it is not clear whether the said order has been accepted by the department or otherwise. Furthermore, such orders are generally limited in their application to the specific facts and parties involved in that particular case and do not necessarily carry binding precedential value.

7.11 I further note that, in the instant case, the subject goods are not stand-alone item/apparatus rather these are goods to be used only as parts of the main apparatus/equipment i.e. Pump for fuel dispensing as discussed herein above. Thus, the goods in question would merit classification as parts of the machinery i.e. Pump for fuel dispensing and should be classified as per Note 2 to Section XVI of the Custom Tariff Act, 1975.

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 Chanter 84 or 85. However, as discussed above the impugned goods i.e. " Display module for fuel pump" are not included in any of the headings of Chapter 84 or 85 and hence could not be classified as per above Note 2(a).

7.11.2 I observe that the Display Module equipped with an LCD screen, decoder IC, and processor IC, plays a crucial role in converting raw operational data (such as the volume and price of dispensed fuel) into a human-readable visual format. This functionality is essential for displaying information to the user in a fuel dispensing system to ensure accuracy and transparency in the fuel transaction. These display modules are specifically designed to be used as integral parts of fuel pumps. Further, Note 2(b) to Section XVI, applies only in cases where such parts cannot be classified as per Section Note 2 (a). In this case, the Display Module equipped with an LCD screen, decoder IC, and processor IC are solely or principally used with fuel pump. As per Note 2(b) to Section XVI of the Customs Tariff Act, 1975, parts that are specifically designed for use with a particular machine should be classified along with that machine.

Since the subject goods serve the purpose of processing and displaying operational data within the fuel dispensing unit and function as essential components of that unit, and since fuel pump are classified under Chapter Heading 8413 as discussed above, it is appropriate to classify the subject goods under the same heading, in accordance with the provisions of Note 2(b) of Section XVI.

7.11.3 I note that Customs Tariff Heading (CTH) 8413 covers fuel pumps as well as their parts as discussed above. However, under the category of parts within this heading, there is no specific mention of display modules or similar components used in fuel pumps. Accordingly, the subject goods i.e., Fuel dispenser display boards/display screens/display module, would fall under the residual entry for parts. Therefore, the subject goods i.e., Fuel dispenser display boards/display screens/display module (Part of fuel pump), is appropriately classifiable under CTI 84139190 {Parts—Other) of the First Schedule of the Customs Tariff Act, 1975, in accordance with Note 2(b) to Section XVI and the Explanatory Notes to Heading 8413.

7.11.4 I also placed reliance on the decision in the case of Crystalonics Displays (P) Ltd. v. Commissioner of Customs (Appeals), Bangalore [2018 (364) E.L. T. 134 (Tri. - Bang.)/, wherein the Hon'ble Tribunal held that LCD modules, which are fitted to instruments for displaying functions such as measuring, checking, and calculating, are neither used as indicator panels nor are they apparatus by themselves. Consequently, the Tribunal concluded that such LCD modules are not classifiable under Tariff Item 8531 20 00 of the Customs Tariff Act, 1975. It was further held that these LCD modules constitute parts, and not complete appliances, and therefore are classifiable under Tariff Item 9033 00 00 of the Customs Tariff Act, 1975, which covers "Parts and accessories (not specified or included elsewhere in this Chapter) for machines, appliances, instruments or apparatus of Chapter 90."

8. The jurisdictional Commissionerate has argued that the subject goods described as Indicator panel equipped with decoder ICs, processor ICs, and backlight do not qualify under CTI 85249190, as Chapter Note 7 to Chapter 85 excludes such modules with signal conversion components from Heading 8524. Further, classification under CTI 85312000 is also incorrect, as the Explanatory Notes to this heading refer to indicator panels used for general signaling purposes (e.g., calling personnel, indicating room status), which is distinct from the function of the subject goods— displaying processed data such as fuel volume, flow, and price from fuel dispensers. Since these modules are specifically designed for use with fuel dispensers, and perform no independent signaling or measurement function, they are deemed to be parts of the machine as per Note 2(b) of Section XVI. Fuel dispensers themselves are classifiable under CTH 8413, which covers pumps for liquids with or without measuring devices, and therefore, the correct classification for the imported indicator panel is under CTI 84139190 as parts of such pumps.

I agree with the view expressed by the jurisdictional Commissionerate that the goods in question merit classification under CTI 84139190 as parts of fuel dispensing pump.

9. On the basis of foregoing discussions and findings, I reach to conclusion that the product under question namely, Fuel dispenser display boards/display screens/display module equipped with LCD Screen, Decoder IC, and Processor IC (referred to by the applicant as 'Indicator Panel"), merit classification under CTH 8413 (Pumps for liquids, whether or not fitted with a measuring device; liquid elevators), more specifically under CTI 84139190 (Parts-Other) of the First Schedule of the Customs Tariff Act, 1975.

10. I rule accordingly.

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

F. No. CAAR/CUS/APPL/09/2025-O/o Commr-CAAR-Mumbai

Dated: 30-05-2025

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

1. M/s. Orpak Systems India Private Limited
Ground Floor, 202, Murhe Vasti,
Pune, Maharashtra-410 501.
{Email: nelson.dsouza@Gilbarco.com}

2. The Pr. Commissioner of Customs,
Chennai-VII, New Customs House,
Air Cargo Complex, Meenambakkam, Chennai- 600016
{Email- pcommr7acc-cuschn@gov.in}

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

5. The Commissioner (Legal), CBIC Offices,
Legal/CX.8A, Cell, 5^th floor, Hudco Vishala Building,
C-Wing, Bhikaji Cama Place, R. K. Puram, New Delhi - 110066.
Email: anishgupta.irs@gov.in, commr.Iegal-cbec@nic.in

6. The Member (Customs), Central Boards of Indirect Taxes & Customs,
North Block, New Delhi-110001.
Email: membercus.cbic@gov.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