2025(05)LCX0526(AAR)

AAR-MUMBAI

Stallion Solutions

decided on 30-05-2025

Customs Authority for Advance Ru

Customs Authority for Advance Rulings 

New Custom House, Ballard Estate, Mumbai - 400 001

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

F.No. CAAR/CUS/APPL/16/2024-25- O/o Commr-CAAR-Mumbai

Date: 30.05.2025


Ruling No. & date CAAR/Mum/ARC/18/2025-26          dated 30.05.2025
Issued by Shri Prabhat K. Rameshwaram,
Customs Authority for Advance Rulings, Mumbai
Name and address of the applicant M/s Stallion Solutions
206, Siddhivinayak Sankul Oak Baugh, Station Road,
KaIyan, Thane, Maharashtra – 421301
Email: sushantacharya@hotmail.com
Concerned Commissionerate The Commissioner of Customs (Import). ACC, Sahar, Andheri (E), Mumbai 400 099

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 jurisdictional 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 - I 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. Stallion Solutions (IEC No.: AFJFS8491M) (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 en -23.01.2025 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 cf Portable Computers in question i.e , Barcode Mobile Computers, RFID Mobile Computers and Tablet Mobile Computer under CTI 8471 3090 of the First Schedule of the Customs Tariff Act, 1975.

2. Applicant's Submissions;

2.1 The Applicant, Stallion S0.iuti.ons, is a partnership firm incorporated in, the year 2024 under the Indian Partnership Act, 1932. The Applicant proposes to. engage in the business of providing Information Technology and Networking Solutions and related services, including the provision of hardware solutions, accessories, and spares. In furtherance of its business, the Applicant is proposing to import certain Portable Computers from its supplier, Newland Taiwan Inc.

2.2 The Portable Computers proposed to be imported fall into three broad categories: (i) Barcode Mobile Computers, (ii) RFID Mobile Computers, and (iii) Tablet Mobile Computers. These categorizations are indicative and based on variations in features, such as processor speed and number of cores, display screen size, presence or absence of keypad, supported Wi-Fi radio standards (802.11 a/b/g/n/ac), battery capacity,' inclusion of automatic identification sensors like barcode scan engines, RFID reader modules, NFC or GPS, and the physical form factor of the device (for example, devices with gun grips for intensive barcode scanning or larger screens for extensive data display). .

2.3 The specific models proposed to be imported under each category are detailed in the submission and are supported with individual product datasheets and photographs. These models include a range of devices with SIM card and Wi-Fi connectivity as well as Wi-Fi-only configurations. Collectively, these devices are referred to as "proposed imports" or "Portable Computers" in this application. A comparative summary of these products is also enclosed by the applicant. The Applicant intends to market these devices further to its network of distributors and consumers, including enterprises involved in supply chain operations such as logistics, warehouse management, e-commerce, government departments (e.g.. Excise), hospitals, and retail outlets.

2.4 The applicant in his submission has stated that in general, Portable Computers are handheld, wearable, or vehicle-mountable computers used for scanning barcodes and real-time data processing to improve operational efficiency in functions like inventory management, last-mile delivery, and invoicing. Functionally, a Portable Computer combines the capabilities of a personal computer and a scanner in a single wireless device, capable of performing 1D and 2D barcode scanning, and equipped with features such as Wi-Fi and Bluetooth connectivity, and data transfer functionalities. Their use spans various warehousing, logistics, and inventory-related operations.

2.5 Portable Computers can typically be categorized into handheld, wearable, vehicle-mounted, and tablet types. This application specifically concerns handheld barcode mobile computers, RFID-enabled mobile computers, and tablet mobile computers. Details on their features and functions are elaborated in Table-ll of .the submission. These devices are small, rugged, and durable, offering extensive field functionality through high-speed wireless connectivity, barcode and RFID scanning, GPS-based location tracking, and Bluetooth-based peripheral integration. Tablet Mobile Computers, in particular, feature larger displays and are intended for high-performance processing and communication in sensitive operational areas

2.6 As described in Table-I, the devices are available in models with SIM card functionality as well as models without. Communication functions are primarily performed using Wi-Fi or wired connectivity, and the cellular network is used only as a fallback where wireless internet is not available, such as during last-mile delivery. Notably, the calling function on SIM-enabled devices is a supplementary feature and not the core functionality, which remains the scanning and processing of data.

2.7 The applicant has further submitted that the classification of goods imported into India is governed by the General Rules of Interpretation (GRI) as set out in the Customs Tariff. Rule 1 of the GRI provides that classification shall be determined according to the terms of the headings and any relevant Section or Chapter Notes. The Indian Tariff is aligned with the Harmonized System of Nomenclature (HSN) up to the six-digit level, and as held by the Hon'ble Supreme Court in Collector of Customs, Bombay v. Business Forms- 2002 (142) ELT 18,.the HSN Explanatory Notes may be used as a reliable guide to interpret the headings of the Tariff.'

2.8 Heading 847T covers automatic data processing (ADP) machines' and units thereof. Sub-heading 847130 specifically relates to "portable digital automatic data processing machine's, weighing not more than 10 kg, consisting of at least a central processing unit, a keyboard and a display." Sub-heading 84713010 covers "Personal Computers," and sub-heading 84713090 covers "Other" portable digital ADP machines. The Portable Computers proposed to be imported by the Applicant fall within the ambit of sub-heading 84713090. , _ '

2.9 As per Chapter Note 6(A) to Chapter 84, an automatic data processing machine must be capable of (i) storing processing programs and necessary data, (ii) being freely - programmable by the user, (iii) performing user-defined arithmetical computations; and (iv) executing programs that modify their execution via logical decisions during processing. The proposed Portable Computers satisfy all these criteria! they are programmable, have data storage capabilities, execute arithmetical computations based on pre-programmed logic, and perform automated functions such as inventory tracking and real-time delivery management. '

2.10 The devices also fulfill the requirement under sub-heading 847130 that they must, weigh not more than 10 kg and include a central processing unit, a keyboard (whether physical or touchscreen), and a display. Thus, the essential structural and functional requirements of a portable ADP machine under Heading 8471 are clearly met.

2.11 Additionally, these Portable Computers are distinct from conventional communication devices because they are equipped with high-grade professional scanning hardware and are primarily designed for enterprise applications involving barcode and RFID scanning. The scanning and processing functions are Integra! to their operation and not incidental.

2.12 Regarding Chapter Notes 6(C), 6(D), and 6(E), these do not affect the classification of the Portable Computers as ADP machines. Note 6(C) pertains to units of ADP machines and is not applicable here, as the subject devices are ADP machines in themselves. Similarly, Note 6(D), which lists excluded products such as printers, communication apparatus, and cameras, applies only to units and not to ADP machines themselves. Note 6(E) refers to machines that perform specific functions other than data processing in conjunction with ADP machines, which again is not relevant as the subject Portable Computers are independently functioning ADP machines and not peripheral or accessory units.

2.13 Accordingly, the Applicant submits that the Portable Computers proposed to be imported satisfy all the conditions laid down under the relevant Chapter Notes and the GRI, and are therefore correctly classifiable under Heading 8471, specifically under Tariff Item 84713090 of the Indian Customs Tariff.

3. Details of Hearing

A hearing was conducted on 09.04.2025 at 1:00 PM. Ms Srinidhi Ganeshan and Ms Anaya Bhide, Advocate/Authorized Representative (AR), appeared online on behalf of the applicant and reiterated the contentions filed in the application and submitted that the subject goods i.e the three models of import goods Barcode Mobile computer, RFID mobile computer and Tablet mobile computer are essentially ADP machines and not mobile communication devices and merit classification under CTI 8471 3090. They also showed and demonstrated the sample of the three subject import goods. They also, relied upon the different case laws including the rulings passed by this authority in the matter of M/s Senate Solutions, M/s Delmon Solutions Pvt. Ltd. and others. They also submitted a compilation of indexes covering the relevant provisions of Customs Tariff and Explanatory Notes and Case laws.

Nobody appeared the hearing from the department side nor comments or submission have been received from the Jurisdictional Commissionerate -Commissioner of Customs (Import), ACC, Sahar, Andheri (E), Mumbai 400 099, in respect of the subject application.

DISCUSSION AND FINDINGS

4. I have taken into consideration all the materials placed before me in respect of the subject goods including all the submissions and citations made by the applicant during the personal hearing. Accordingly, I proceed to pronounce a ruling on the basis of information available on record as well as existing legal framework having bearing on the classification of the goods in question under the first schedule of the Customs Tariff Act, 1975, specifically Chapter 84 & 85, its corresponding Chapter notes, supplementary notes and relevant HSN explanatory notes.

4.1 The matter pertains to the classification of  enterprise grade portable computing devices—namely Barcode Mobile Computers, RFID Mobile Computers, and Tablet Mobile Computers—to be imported by the Applicant, Stallion Solutions. This issue is squarely covered under Section 28H(2)(a) of the Customs Act, 1962, as it relates to the classification of goods under the provisions of this Act.

4.2 To determine the correct tariff classification of the proposed goods, it's important to first identify the specific nature and function of the product. The Applicant, in his submission proposes to import various enterprise-grade Portable Computers— namely Barcode Mobile Computers, RFID Mobile Computers, and Tablet Mobile Computers as detailed below in Table I from its supplier, Newland Taiwan Inc.

Table -1

Sr No  Device Category Mobile Computer Models Wireless Connectivity Options Product Datasheet and Photo Enclosed as
1 Barcode Mobile  Computers NLS-MT37H Portable Data Collector Device with SIM Card & Wi-Fi Exhibit 1(A)
Wi-Fi Only Device Exhibit 1(B)
2 NLS-N7 Portable Data Collector Device with SIM Card & Wi-Fi Exhibit 2(A)
Wi-Fi Only Device Exhibit 2(B)
3 NLS-N7 Portable Data Collector Device with SIM Card & Wi-Fi Exhibit 3(A)
Wi-Fi Only Device Exhibit 3(B)
4 NLS-MT65 Portable Data Collector Device with SIM Card & Wi-Fi Exhibit 4(A)
Wi-Fi Only Device Exhibit 4(B)
5 NLS-MT67 Portable Data Collector Device with SIM Card & Wi-Fi Exhibit 5(A)
Wi-Fi Only Device Exhibit 5(B)
6 NLS-MT90 Portable Data Collector Device with SIM Card & Wi-Fi Exhibit 6(A)
Wi-Fi Only Device Exhibit 6(B)
7 NLS-MT95 5G Portable Data Collector Device with SIM Card & Wi-Fi Exhibit 7(A)
Wi-Fi Only Device Exhibit 7(B)
8 NLS-MT93 4G Portable Data Collector Device with SIM Card & Wi-Fi Exhibit 8(A)
Wi-Fi Only Device Exhibit 8(B)
9 NLS-MT93 Lite 4G Portable Data Collector Device with SIM Card & Wi-Fi Exhibit 9(A)
Wi-Fi Only Device Exhibit 9(B)
10 NLS-NFT10 Portable Data Collector Device with SIM Card & Wi-Fi Exhibit 10(A)
Wi-Fi Only Device Exhibit 10(B)
11 RFID NLS-MT 93-U 4G RFID/UHF Mobile computer Device with SIM Card & Wi-Fi Exhibit 11(A)
Wi-Fi Only Device Exhibit 11(B)
12 Mobile computer SD60RT Mobile Computer Device with SIM Card & Wi-Fi Exhibit 12(A)
Wi-Fi Only Device Exhibit 12(B)
13 Tablet Mobile Computer SDIOO 10 inch TABLET with 4G/5G Device with SIM Card & Wi-Fi Exhibit 13(A)
Wi-Fi Only Device Exhibit 13(B)
14 SP 80 10.1 inch industrial tablet with 4G/5G Device with SIM Card & Wi-Fi Exhibit 13(A)
Wi-Fi Only Device Exhibit 13(B)
15 SP 80 8 inch industrial tablet with 4G/5G Device with SIM Card & Wi-Fi Exhibit 13(A)
Wi-Fi Only Device Exhibit 13(B)

These devices are categorized into three primary types arid are characterized by features such as barcode scanners, RFID readers, Tablet mobile computers having GPS modules, robust processing units, and touch-based display screens. They operate on configurable enterprise-grade operating systems (e.g., Android or Windows), are freely programmable by the user, and are designed for intensive enterprise usage in sectors such as logistics, warehousing, asset tracking, government services, and retail operations. The devices come in both Wi-Fi-only and SIM-enabled variants, depending on the requirement of the deployment environment.

4.3 The Applicant submitted that portable computers are generally classified into the following categories:

However, the present application specifically concerns three types of portable computers, which are detailed below :

Table - II

Product Name Illustrative Image Key features/functions performed
Barcode
Mobile
Computers

(have bar code scan engine)
  'These are small, vet durable devices that extend
organizational knowledge into the field by combining scanning and processing functions into a single device.

-ID and 2D scanning of barcodes

-Securely access programs or databases stored in the cloud or your office using the latest Wi-Fi technologies

- Take advantage of high-speed WLAN or WWAN networks

- Add additional memory using expandable card slots

- Accurately pinpoint the locations of employees, assets, and businesses with optional GPS capabilities

- Easily sync with modems, printers, and headsets using Bluetooth wireless connectivity

- Always stay connected via phone using integrated cellular service (for some models which can accommodate sims)

RFID
Mobile
Computer

(have RFID reader)
 

These devices are adding the new capabilities with integrated UHF/RAIN RFID readers.

- ID and 2D scanning of barcodes.

- Securely access programs or databases stored in the cloud or office using the latest Wi-Fi technologies.

-Take advantage of high-speed WLAN networks.

- Add additional memory using expandable card slots.

-Accurately pinpoint the locations of employees, assets, and businesses with optional GPS

Tablet Mobile Computer
(Tablet with Displays larger than the above 2 categories of Portable Computers)
  Handheld computers for undertaking processing and communication activities in sensitive areas.


4.4 The Applicant submitted that the devices in question are rugged, portable digital automatic data processing machines equipped with features such as barcode and RFID scanners, wireless connectivity, and programmable processing capabilities. They further submitted that these devices are primarily utilized in industrial sectors including logistics, warehousing, retail, and e-commerce. The Applicant contended that the devices fulfill all the structural and functional requirements specified in Chapter Note 6(A) to Chapter 84 and, therefore, are appropriately classifiable under Heading 8471, specifically under Tariff Item 84713090 of the Indian Customs Tariff.

4.5 Before deciding on the issue, let me deliberate on the legal framework prescribed in Customs Tariff Act, 1975, Chapter/ Section notes along with HSN explanatory notes. Classification of imported goods is governed by the principles set forth in the General Rules of Interpretation (GIR). The General Rules of Interpretation (GIR), along with Chapter Notes, Section Notes, and HSN Explanatory Notes, guide the proper classification of imported goods based on their nature, function, and composition. GRI 1 (General Rules of Interpretation) of Customs Tariff Act, 1975 provides that the classification of goods shall be "determined according to the terms of the headings and any relative section or chapter notes." In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, GRIs 2 through 6 may be applied in order. In order to merit classification under heading 8471, it is clear, that these devices need to satisfy the requirements of note 6(A) to chapter 84, the said chapter note is reproduced below: -

For the purposes of heading 8471, the expression "automatic data processing machines, means machine capable of:

(I) storing the processing programme or programmes and at least the data immediately necessary for the execution of the programme, ,

(ii) being freely programmed in accordance with the requirements of the user;

(iii) performing arithmetical computations specified by the user; and -

(iv) executing, without human intervention, a processing programme which requires them to modify their execution, by logical decision during the processing run.

Therefore, there is a need to examine whether the features and specifications of the devices under consideration meet the criteria as laid down in the relevant chapter note reproduced above. The impugned devices, appear to be able to-satisfy the requirements of an ADP machine. Note 6(C) to Chapter 84 specifies the conditions for a unit to be classified as being part of an automatic data processing system which is reproduced below:

6(C)-Subject to paragraphs (D) and (E), a unit is to be regarded as being part, of an automatic data processing system if it meets all of the following conditions:

(i) it' is of a kind solely or principally used in an automatic data processing system; -

(ii) it is connectable to the central processing unit either directly or through one or more other units; and

(iii) it is able to accept or deliver data in a form (codes or signals) which can be used by the system. Separately presented units of an automatic data processing machine are to be classified in heading 8471. However, keyboards,-X-Y co-ordinate input devices and disk storage units which satisfy the conditions of (ii) and (Hi) above, are in all cases to be classified as units of heading 8471.

4 6 However, from the working and features of the impugned, devices, it appears that these are not units of ADP machines, but. ADP machines themselves. Note 6(D) to chapter 84 lists certain separately presented products that are to oe excluded from heading 8471, even if they can be classified as part of an ADP system. Note 6(E) to chapter 84 mentions that a machine incorporating-or working in conjunction with an automatic data processing machine and performing a specific function ether than data processing are to be classified in the headings appropriate to their respective functions or, failing that, in residual headings. As the impugned devices, as described by the applicant, appear to be akin to ADP machines performing capturing of data and its further processing, notes 6(D) and 6(E) do not appear to have application in this case.

4.7 The devices proposed for import satisfy the above conditions. They contain a central processing unit, a display screen, and a keyboard (either physical or virtual), and are capable of executing complex enterprise applications such as ERP, WMS, and logistics tracking. Further, they are designed for data processing, not for voice telephony or general personal communication, which disqualifies them from classification under Heading 8517.

4.8 Subheading 8471 30 of the Tariff covers portable digital ADP machines weighing not more than 10 kg and consisting of at least a CPU, a keyboard, and a display. These devices meet those physical and technical requirements and are therefore classifiable under Tariff Item 84713090.

4.9 The WCO Explanatory Notes to Heading 8471 support this position, stating that mobile terminals or rugged handhelds used in logistics, asset control, and field services qualify as ADP machines if their main function is data processing. The addition of barcode scanners, RFID modules, or SIM-Dased communication capability does not alter their principal function if such modules merely facilitate data capture or transmission.

4.10 This understanding is further affirmed by CBIC Circular No. 20/2013-Customs dated 14.05.2013, which provides explicit and authoritative guidance on the classification of rugged mobile terminals. The Circular, while addressing classification issues related to enterprise-grade handheld mobile computing devices, clarified that such devices—when intended primarily for data processing ' and enterprise applications such as warehouse management, retail automation, or logistics tracking—must be classified under Heading 8471. The Circular specifically noted that the presence of communication modules like GSM/GPRS/3G/4G for data transmission does not change the essential character of the device. It recognized the industry-wide understanding that these devices function predominantly as portable computing terminals and not as telecommunications equipment. This interpretation has been cited repeatedly in customs practice and continues to hold binding value under Section 151A of the Customs Act, 1962.

4.11 Further reinforcement of this classification approach is found in the recent rulings ' concerning the classification of similar products—namely, Portable Computers—the Customs Authorities for Advance Rulings, in the cases of M/s. Senate Solutions Pvt. Ltd., M/s. Brightpoint India Pvt. Ltd., M/s. Rashi Peripherals Pvt. Ltd., and M/s. RET-Tech Pvt. Ltd., have consistently held that such devices are classifiable under sub-heading 8471 3090. Upon examining the reasoning provided in these rulings, I find that the Authorities have comprehensively evaluated all relevant aspects before arriving at their conclusions. The devices in question are handheld, portable computing units designed for enterprise use, capable of running mobile applications, scanning barcodes, capturing photos and videos, and facilitating voice and data communications. They integrate the functions of a personal computer and a scanner in a single wireless unit, and can operate using standard or customized software for functions like delivery monitoring-, asset, tracking, and inventory management. Operating on common platforms such as Android or Windows, they offer functionality comparable to desktop or laptop computers. Equipped with integrated barcode scan engines and onboard processing capabilities, these devices act as self-sufficient hosts, enabling real-time data capture and processing. In light of the above, I find the applicant has rightly suggested classification under Customs Tariff Heading 8471.

4.12 Upon examination of the possible alternative classification under Heading 8517, it is pertinent to assess the features of the subject devices in the context of Note 3 to Section XVI of the Customs Tariff. Heading 8517 covers "Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks; other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network), other than transmission or reception apparatus of Heading 8443, 8525, 8527 or 8528." Given that certain models are equipped with cellular communication functionality, the possibility of classification under this heading warrants consideration.. However, Note 3 to Section XVI provides that, "unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole, or other machines designed to perform two or more complementary or alternative functions, shall be classified as if consisting only of that component or as being that machine which performs the principal function". In the instant case, while the devices incorporate communication capabilities, their primary and defining function is that of automatic data processing, including enterprise-level tasks such as inventory management, asset tracking, and delivery monitoring— facilitated through integrated computing and scanning features. The communication functions, including cellular connectivity, are auxiliary in nature and comparable to those found in conventional desktop or laptop computers. Therefore, it is evident that the principal, function of these devices is that of automatic data processing, which must guide their classification ,

4.13. In Circular No. 20/2013-Custo.ms, dated 14,05.2013, the Central Board of Excise and Customs provided a clear clarification regarding the classification of "tablet computers" under Heading 8471. The, Board observed that "...The mobile phone calling function could be provided by the products only as a supplementary function because it could not be activated without running an operating systern of the devices.,... These devices are not intended to be a substitute for a mobile phone to make voice calls, but, according to its main technical features is designed as a substitute' for laptops. The difference between a 'smartphone' and 'tablet computer', is not based on whether the product has a voice calling function or not, but on the principal features that a producer has intended for the device when designing and developing it."

4.14 Accordingly, as per the said circular, tablet computers are to be classified under Heading 3471 and not under Heading 8517, notwithstanding the presence of cellular connectivity, as the principal function remains automatic data processing. By parity of reasoning, the devices under consideration—designed primarily for barcode scanning and data processing functions .such as monitoring deliveries, tracking assets, and managing inventory—are not intended to function primarily as communication devices. Therefore, the principal function of these devices aligns, with that, of automatic data processing' machines, and they are consequently more appropriately classifiable under Heading 8471 rather than under Heading 8517. .

4.15 In relation to the classification opinion issued during the 68th Session of the Harmonized System Committee, it is noted that the Committee classified RFID/barcode readers equipped with a mobile operating system and cellular connectivity under subheading 8517.13, which pertains to smartphones. Note 5 to Chapter 85 defines smartphones for the purposes of Heading 8517 as "telephones for cellular networks, equipped with a mobile operating system designed to perform the functions of an automatic data processing machine such as downloading and running multiple applications simultaneously, including third-party applications, and whether or not integrating other features such as digital cameras and navigational aid systems."

4.16 Tnis definition makes it clear that the classification under subheading 8517.13 applies to devices that are fundamentally telephones for cellular networks, albeit with advanced computing capabilities. However, the devices under consideration in the present case are not principally telephones for cellular networks. In fact, 15 out of the 30 models lack cellular connectivity altogether, demonstrating that a SIM card is not integral to their functioning. These devices are capable of executing their core functions—namely barcode scanning, data processing, and enterprise-level data management—irrespective of the presence of a SIM card. Furthermore, they are not designed for telephony as their principal function.

4.17 As clarified in Circular No. 20/2013-Customs, dated 14.05.2013, "the difference between a 'smartphone' and 'tablet computer is not based on whether the product has a voice calling function or not, but on the principal features that a producer has intendod for the device when designing and developing it." In line with this rationale, the devices in question are best characterized as automatic data processing (ADP) machines with auxiliary connectivity features, including cellular connectivity.

4.18 CBiC Instructions No. 01/2022-Customs and 25/2022-Customs further consolidate this approach. Instruction No. 01/2022 stresses reliance on WCO Explanatory Notes and GIRs for classifying multifunctional goods, while Instruction No. 25/2022 reaffirms that classification must be based on essential character. Both instructions emphasize that incidental functions, such as wireless connectivity, cannot override the principal ADP function.

4.19 A detailed comparison, as presented by the applicant of the submission, underscores the functional and technical distinctions between these enterprise-grade devices and consumer-grade smartphones. The impugned devices possess advanced features such as superior scanning capabilities, ruggedized construction, and robust enterprise security protocols—attributes typically absent in standard smartphones. Their use is concentrated in enterprise settings for tasks like inventory management, order processing, package tracking, and goods delivery. Primary data transfer occurs via Wi-Fi and Bluetooth, while cellular connectivity is employed only in limited cases for GPS services and data transmission in Wi-Fi-deficient environments. The occasional use of voice calling is incidental and not central to their intended purpose. However, as noted earlier, 15 out of the 30 models lack cellular connectivity. In light of the foregoing discussion and the facts on record, it is my considered view that the devices in question do not qualify for classification as smartphones. Accordingly, they are appropriately classifiable under subheading 8471 30 90.

4 20 The Hon'ble Supreme Court in Atul Glass Industries Ltd. v. Collector of Central Excise [1986 (25) E.L.T. 473 (S.C.)] held that classification should be based on the commercial understanding of the product The Court observed that the trade identity and usage of the goods must be factored into the classification process. Similarly, in Commissioner of Central Excise v. Wockhardt Life Sciences Ltd. [2012 (277) E.L.T. 299 (S.C.)], the Court stressed that when goods have multiple uses or functions, classification should be based on the essential character of the goods, as per GIR 3(b).

4.21 Further, the approach is consistent with international best practices followed by customs administrations globally. The reliance on the principal function test, the use of WCO Explanatory Notes, and the interpretation of composite goods under GIR 3(b) are not only consistent with domestic guidance but are also endorsed by international jurisprudence and WCO Council Recommendations. Applying these judicial principles and administrative instructions, it is evident that the primary utility of the proposed devices lies in data processing and enterprise deployment. The inclusion of SIM slots or communication features does not change their essential character, which remains computing-centric. Hence, the classification under Heading 3517 is both technically and legally untenable.

4.22 Accordingly, it is conclusively held that Barcode Mobile Computers, RFID Mobile Computers, and Tablet Mobile Computers, which are rugged., portable, freely programmable, and built for enterprise-grade ADP functionality, are appropriately classifiable under Tariff Item 84713090 of the First Schedule to the Customs Tariff Act, 1975, as "Other portable digital automatic data processing machines."

5. In view of the foregoing analysis and conclusions, I hereby hold that the 30 devices enumerated in the Table-I (Para 4.2) of this ruling are classifiable under Heading 8471, and more precisely, under Subheading 8471 30 90 of the First Schedule to the Customs Tariff Act, 1975.

6. I rule accordingly.

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

F. No. CAAR/CUS/APPL/16/2024-25-0/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 Stallion Solutions,
206, Siddhivinayak Sankul Oak Baugh,
Station Road, Kalyan, Thane, Maharashtra - 421301
Email: sushantacharya@hotmail.com

2. The Commissioner of Customs(lmport),
ACC, Sahar, Andheri (E), Mumbai 400 099

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 400 001.
Email : ccu-cusmum1@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: commr.legal-cbec@nic.in

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

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

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