2025(06)LCX0399(AAR)

AAR-MUMBAI

Valeo India Private Limited

decided on 20-06-2025

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/32/2025 - O/o Commr-CAAR-Mumbai

Date: 20.06.2025

Ruling No. & date CAAR/Mum/ARC/ 37/2025-26               dated 20.06.2025
Issued by Shri Prabhat K. Rameshwaram,
Customs Authority for Advance Rulings, Mumbai
Name and address of the applicant M/s. Valeo India Private Limited
CEE DEEYES IT Park, Block No. 1,
No. 63, Rajiv Gandhi Salai, Navalur,
Chennai-600 130.
{Email: dinesh-raia.r@valeo.com}
Concerned Commissionerate The Commissioner of Customs, Chennai-VII,
New Customs House, Air Cargo Complex,
Meenambakkam, Chennai- 600016.
Email- pcommr7acc-cuschn@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 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. Valeo India Private Limited (IEC No.: 0508058899) (hereinafter referred to as 'the Applicant’) filed an application (CAAR- 1 ) for advance ruling in the Office of Secretary, Customs Authority for Advance Ruling (CAAR) Mumbai. The said application was received in the secretariat of the CAAR, Mumbai on 18.02.2025 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 the Clutch Master Cylinder (CMC) and Concentric Slave Cylinder (CSC) under CTH 8412 as a Linear Acting (Cylinders), or under CTH 8708 as parts of motor vehicle of heading 8701 to 8705, of the First Schedule of the Customs Tariff Act, 1975.

2. Submission by the Applicant:

2.1 M/s. Valeo India Private limited ("the Applicant"), a Private Limited company is engaged in the manufacture of automobile components and has a strong presence in areas of Mechanical Design, Simulation, Embedded Software Development, Vision Systems Software and Hardware and Functional Safety Design.

2.2 The applicant is importing Clutch Master Cylinders and Concentric Slave Cylinders (hereinafter referred to as "CMC and CSC"), which are used in motor vehicle's clutch system. Though the CMC and CSC may not look the same, they are integral parts of the hydraulic clutch system,

Function and Composition of 'CMC'

2.3 A CMC is a component of a car clutch system, specifically semi- hydraulic and fully- hydraulic clutch systems and is used to transfer the clutch pedal movement to the clutch via hydraulic fluid. The CMC consists of a body, piston, primary seal, secondary seal, a push rod, a low-pressure nozzle and a high-pressure nozzle. The body is made up of aluminium or plastic and the piston is made up of anodized aluminum. The primary seal of the CMC is used to isolate the reservoir from the hydraulic chamber and the secondary seal is used to isolate the low-pressure reservoir chamber from its environment. The Push rod is used to connect the CMC to the pedal. The low-pressure nozzle is used for connecting the CMC to the reservoir and the high-pressure nozzle is used for connecting the CMC to the high-pressure pipe and the receiver

2.4 The CMC is connected to a plastic or metal tank filled with hydraulic fluid and this fluid reservoir tank is sometimes shared with the brake master cylinders. The CMC acts as a transmitter in the hydraulic system, sending the input of the driver to the clutch via the clutch release cylinder. A picture of the CMC is shown below.

 

 

Function and Composition of ’CSC'

2.5 A CSC is a hydraulic cylinder with an integrated release bearing which eliminates the clutch fork and the conventional release bearing. The CMC provides a smooth operation of clutch pedal and also reduces the pedal effort. It is made of Aluminium housing and fitted on the gearbox input shaft.

2.6 This CSC is made up of a material which is much lighter than the standard clutch system command. The CSC will be in direct contact with the clutch cover diaphragm, which will increase the efficiency of the hydraulic system, it is used to eliminate the fork and release the bearing. It is concentric to the gear box input shaft

A diagram of the CSC is shown below

 

 

2.7 Notably, both the CMC and CSC are hydraulic cylinders and are parts of the clutch actuation system in a motor vehicle. The CMC and CSC as located in a clutch actuation system are pictorially depicted below

 

 

2.8 Clutch components with actuation system (Picture 3 above) are as follows

1. Dual mass flywheel

2. Clutch cover

3 . Mechanical releaser

4. Pedal vibration damping device

5. Clutch Master Cylinder (CMC)

6. Plastic Clutch Pedal

7. Clutch Slave Cylinder (CSC)

8. Clutch (friction) disc

2.9 Below is a diagrammatic depiction of the Clutch actuation system:

 

 

1. Master cylinder
2. Reservoir
3. Piston
4. High pressure line (pipe)
5 . Slave cylinder
6. Pushrod

2.10 The clutch pedal is linked directly to the piston (3) of the master cylinder (1). When the driver pushes the clutch pedal, the piston moves within the master cylinder and compresses the hydraulic fluid building up pressure. The pressure is transmitted through the high-pressure pipe (4) to the slave cylinder (5). The pushrod (6) is connected to the piston of the salve cylinder. Due to the increase of pressure in the slave cylinder, the pushrod is pushed outside acting on the clutch fork, which releases the pressure plate and opens the clutch. The hydraulic fluid used for actuation is usually brake fluid or mineral oil. The working of the CSC is depicted in the picture below.

 

 

2.11 it could be seen that both the CMC and CSC are essentially linear acting hydraulic cylinders, and their operation depends on the hydraulic pressure created by the hydraulic fluid.

3. Applicants interpretation of Law/Facts:

APPLICANT’S ELIGIBILITY TO SEEK ADVANCE RULING

3.1 The Applicant is eligible to seek an advance ruling under the Customs Act, 1962. As per Section 28E(c) of the Act, an "applicant" is defined as a person holding a valid Importer-Exporter Code (IEC) under the Foreign Trade (Development and Regulation) Act, 1992. The Applicant holds a valid IEC (No. 0508058899), satisfying this requirement. The present application seeks an advance ruling on the classification of "Clutch Master Cylinder and Clutch Slave Cylinder" under Section 28H of the Customs Act, which allows rulings on the classification of goods, applicability of duty notifications, and determination of the origin of goods. The application pertains to goods before their importation, fulfilling the condition under Section 28E(b).

3.2 The bar under Section 28-1 of the Customs Act does not apply in this case. Section 28-1 prohibits applications only if the issue is already pending or decided by any customs authority or court. The Applicant confirms that no similar case is pending in any forum. The Applicant submits that each import constitutes a separate taxable event, as held in Jain Exports Pvt. Ltd. v. Union of India, 1987 (29) E.L. T 753 (Det.), and reaffirmed by the Supreme Court in 1992 (61) E.L.T. 173. This supports the position that an advance ruling can be sought for each import as a separate event. The Applicant also relies on Samsung Noida Display Pvt. Ltd. Vs The Commissioner of Customs [ 2024 (390) E.L.T. 73 (A.A.R. Cus. Det.], where it was held that advance rulings remain maintainable even for previously imported goods, provided the ruling pertains to future transactions and is not under dispute. Similarly, in Amazon Seller Services Pvt. Ltd. , (2023) 5 Centax 186 (H . A. R Cus. Mum.) , it was held that advance rulings can be sought for ongoing activities if no litigation or dispute is pending on the same issue.

3.3 The Applicant meets all the necessary conditions for seeking an advance ruling: holding a valid IEC, filing the application before importation, raising a valid question under Section 28H(2)(a), and ensuring no bar under Section 28-1 applies. Therefore, the present application is legally maintainable and should be allowed to proceed.

Classification under CTH 8412

3.4 Chapter 84 of the First Schedule to the Customs Tariff Act, 1975 covers goods, described as " Nuclear Reactors, Boilers, Machinery and Mechanical Appliances; Parts Thereof' . The chapter falls under Section XVI, titled "Machinery and Mechanical Appliances; Electrical Equipment; Parts Thereof; Sound Recorders and Reproducers, Television Image and Sound Recorders and Reproducers; and Parts and Accessories of such articles" .

3.5 Heading (CTH) 8412 reads as " Other engines and motors" . The relevant HSN ENs under CTH 8412 is extracted below:

"(B) HYDRAULIC POWER ENGINES AND MOTORS

This group includes :

(1) Certain engines, other than turbines or wheels of heading 84.10, producing mechanical power by utilising the energy of the waves or sea swell (Savonius rotor with two semicylindrical bladings) or of the tides

(2) Water column machines operating by the pressure of water on pistons. The water acts on two or more pistons moving inside the (cylinders which in turn drive a shaft.

(3) Hydraulic cylinders consisting, for example, of a brass or steel barrel and a piston operated by oil (or other liquid) under pressure applied on one side (single-acting) or on both sides (double-acting) of the piston, the energy of the liquid under pressure being converted into a linear motion. These cylinders are used on machine-tools, construction machines, steering mechanisms, etc.

(4) Hydraulic valve actuators, presented separately, consisting of a metal casing containing a piston which, by means of a pin perpendicular to the piston rod, converts the linear motion caused by the action of a liquid under pressure into a rotary motion, in order to operate a plug valve or other appliance with a  rotating mechanism.

(5) Hydraulic servomotors which perform the role of final or intermediate actuators in feedback control systems or regulating systems. These servomotors are used, e.g., in aircraft.

(6) Hydraulic systems consisting of a hydraulic power unit (comprising essentially a hydraulic pump, cm electric motor, control valves and an oil tank), hydraulic cylinders and the pipes or hoses needed to connect the cylinders to the hydraulic power unit, the whole forming a functional unit within the meaning of Note 4 to Section XVI (see the General Explanatory Note to that Section). These systems are used, e.g., to operate civil engineering structures." (emphasis supplied)

3.6 From the pictures, description and function of CMC and CSC as discussed above, it can be observed that both are essentially linear acting hydraulic cylinders. The Hydraulic cylinders referred to at St. No 3 above, under the category Hydraulic engines are identical to the CMC and CSC in question. CTH 8412 2100 is specific inter alia, to these types of cylinders.

3.7 It is therefore apparent that the CMC and CSC in question could remain under CTH 84122100 as linear acting hydraulic cylinders in terms of GIR 1 read with the HSN ENS cited supra. Thus, by application of GIR 1, classification of the CMC and CSC in question under CTH 84122100 can be justified.

Classification under Heading 8708

3.8 Chapter 87 of the First Schedule to the Customs Tariff Act, 1975 covers goods, described as "Vehicles other than railway or tramway rolling-stock, accessories thereof’ . Chapter Bl is covered under Section XVII (vehicles, aircraft, vessels and associated transport equipment).

3.9 Chapter Heading 8708 covers " Parts and accessories of the motor vehicles of headings 8701 to 8705" . Since the CMC and CSC in question are designed for use in the Clutch actuation system of motor vehicles, and are identifiable parts of motor vehicles, the feasibility of them being classified as a part of a motor vehicle under CTH 8708 is discussed below:

3.10 The EN to Heading 87.08 reads as follows:

"This heading covers parts and accessories of the motor vehicles of headings 87.01 to 87.05, provided the parts and accessories fulfil both the following conditions:

(i) They must be identifiable as being suitable for use solely or principally with the above-mentioned vehicles; and

(ii) They must not be excluded by the provisions of the Notes to Section XVII (see the corresponding General Explanatory Note) ".

3.11 The HSN Explanatory Notes under Section XVII lay down the most important principle for classification of parts and accessories of the goods of Section XVII thus:

"(III) PARTS AND ACCESSORIES

"It should be noted that Chapter 89 makes no provision for parts (other than hulls) or accessories of ships, boats or floating structures. Such parts and accessories, even if identifiable as being for ships, etc., are therefore classified in other Chapters in their respective headings. The other Chapters of this Section each provide for the classification of parts and accessories of the vehicles, aircraft or equipment concerned.

It should, however, be noted that these headings apply only to those parts or accessories which comply with all three of the following conditions:

(a) They must not be excluded by the terms of Note 2 to this Section and

(b) They must be suitable for use solely or principally with the articles of Chapters 86 to 88 and (c) They must not be more specifically included elsewhere in the Nomenclature (emphasis supplied)."

3.12 It could be seen that for classification of parts and accessories of the goods of Section XVII, satisfaction of all the three conditions cumulatively is a must. The first condition is that the part/ accessory in question should not be excluded by Note 2 ibid. In this regard Note 2(e) ibid, which is relevant is extracted below:

"2. The expressions "parts" and "parts and accessories" do not apply to the following articles, whether or not they are identifiable as for the goods of this Section:

(a) - (d)

(e) machines and apparatus of headings 8401 to 8479, or parts thereof other than the radiators for the articles of this Section, articles of heading 8481 or 8482 or, provided they constitute integral parts of engines and motors, articles of heading 8483."

3.13 It is thus apparent that in terms of Note 2 (e) to Section XVII, machines and apparatus of headings 8401 to 8479, or parts thereof, are not regarded as parts or accessories of motor vehicles, even when they are identifiable for use with the motor vehicles. As already discussed supra, the CMC and CSC in question, being essentially linear acting hydraulic cylinders, they are specifically covered under CTH 84122100 by application of GIR 1.

3.14 Therefore, even granting that the CMC and CSC in question are identifiable for use solely or principally with the motor vehicles, for the reason that they are excluded by Note 2 (e) ibid, their classification under Section XVII and more specifically under CTH 8708 can be ruled out.

3.15 Further, as discussed supra, by application of GIR 1, the CMC and CSC are more specifically covered under CTH 84122100. Therefore, the third condition is also not satisfied, notwithstanding the fact that the sensor is identifiable for use with motor vehicles.

3.16 This classification principle has been accepted by the Hon'ble Supreme Court in the case of Commissioner of Central Excise, Delhi-IH v. Uni Products India Ltd., which principle has also been reiterated by CBIC in their Instructions No 1/2022 Customs dated 5-1-2022 and 25/2022 Customs dated 3-10-22 issued in the light of the Hon'ble Supreme Court decision in the matter of Westinghouse Saxby Farmer Ltd. Versus Commr. of Central Excise Calcutta.

3.17 Therefore, classification of the CMC and CSC in question under CTH 8708 only on the ground that these components are identifiable for use solely or principally with motor vehicles in question will not be appropriate.

3.18 It is therefore apparent that classification of CMC and CSC in question under CTH 84122100 will be appropriate in terms of GIR 1 read with Note 2(e) to Section XVII and for the same reasons classification of the CMC and CSC in question under CTH 8708 and more specifically under CTH 8708 9300 as parts of clutches of motor vehicles can be ruled out.

3.19 The American Customs in their Ruling No HQ HI95876 dated March 24, 2016 dealt with identical components. In this ruling, the American Customs revoked their earlier ruling for these components under CTH 87089375 and approved the classification of the CMC under CTH 8413 5000 as a reciprocating positive displacement pump, while approving the classification of CSC under CTH 8412 2100.

3.20 While this ruling has clearly ruled out classification of CMC and CSC under CTH 87089375 correctly, in our view the suggested classification for CMC under CTH 84135000 as reciprocating positive displacement pump, may not be correct as pumps are defined by the HSN ENs under CTH 8413 as under :

"This heading covers most machines and appliances for raising or otherwise continuously displacing volumes of liquids (including molten metal and wet concrete), whether they are operated by hand or by any kind of power unit integral or otherwise."

Therefore, the requirement for classification of a pump under CTH 8413 is raising or otherwise continuously displacing volumes of liquids. In other words, continuous action of raising or displacement is a sine qua non for an equipment to be regarded as a pump classifiable under CTH 8413.

3.21 In the case of CMC there is no such raising or continuous displacement of hydraulic fluid. Only when the clutch pedal is pressed, this mechanical action is transformed into hydraulic pressure by the action the piston moving inside the cylinder. This function is more specifically covered under CTH 8412 as already discussed supra.

3.22 Therefore, in our view classification of the CMC as a linear acting hydraulic cylinder under CTH 8412 is appropriate. This ruling has nevertheless approved the classification of CSC under CTH 84122100 and has also ruled out classification of CMC and CSC under CTH 87089375 as parts of clutches of automobiles.

3.23 The Applicant also draws reference to German Ruling DEBT151081/21-1 dated 03/02/2022 and French Ruling FRBTIFR-BTI-2022-03884 dated 01/07/2022, where Clutch Master Cylinder have been classified under CTH 8412.

3.24 For all the reasons discussed supra, we submit that the CMC and CSC in question would be appropriately classifiable under CTH 84122100 as linear acting hydraulic cylinders.

3.25 Given the highly technical nature of the data relating to the subject products being discussed and provided in the application, they respectfully request that the information provided therein be treated as confidential. The application contains detailed technical information on the products that only unique to the applicant, and crucial to their competitive edge. Public disclosure of such technical data could potentially provide competitors with an unfair advantage, thereby compromising the applicant's business interests. They therefore kindly request that the ruling, along with any related information not be published, to prevent any unintended dissemination of sensitive and critical technical information.

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. Clutch Master Cylinder (CMC) and Concentric Slave Cylinder (CSC) 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 05.03.2025.

The concerned jurisdictional Commissionerate vide their letter dated 08.04.2025 has submitted as follows:

i. They must not be excluded by the terms of Note 2 to this Section, and

ii. They must be suitable for use solely or principally with the articles of Chapter 86 to 88 Section, and

iii. They must not be more specifically included elsewhere in the Nomenclature Section"

"Parts and accessories of this heading include:

xxxx

(C) Clutches (cone, plate, hydraulic, automatic, etc., hut net the electro magnetic clutches of heading 85.05), clutch casings, plates and levers, and mounted linings.
Xxxx

(H) Brakes (shoe, segment, disc, etc.) and parts thereof (plates, drums, cylinders, mounted linings, oil reservoirs for hydraulic brakes, etc.); servo brakes and parts thereof

Xxxx"

Therefore, from the above, it appears that Clutch Master Cylinder (CMC) and Clutch Slave Cylinder (CSC) are rightly classifiable under CTI 8708 9300.

"If there is no meaning attributed to the expressions used in the particular enacted statute then the items in the customs entries should be judged and analysed on the basis of how these expressions are used in the trade or industry or in the market or, in other words, how these are dealt with by the people who deal in them, provided that there is a market for these types of goods. This principle is well known as classification on the basis of trade parlance. This is an accepted form of construction. It is a well-known principle that if the definition of a particular expression is not given, it must be understood in its popular or common sense viz. in the sense how that expression is used every day by those who use or deal with those goods. "
 

" ..........there is no one single universal test in these matters. The several decided cases drive home this truth quite eloquently............. There may be cases, particularly in the case of new products, where this test may not be appropriate. In such cases, other tests like the test of predominance, either by weight of value or on some other basis may have to be applied. It is indeed not possible, nor desirable, to lay down any hard and fast rides of universal application".

Further, the Hon'ble Supreme Court, in the case of Commissioner of Central Excise, Mumbai v. M/s. Fiat India (P) Ltd. [2012 (283) E.L.T. 161 (S.C.)], has observed that, -

"a case is only an authority for what it actually decides and not for what may seem to follow logically from it. ...Each case depends on its own facts and a close similarity between one case and another is not enough because either a single significant detail may alter the entire aspect... To decide, therefore on which side of the line a case falls, the broad resemblance to another case is not at all decisive."

5. Rebuttal

5.1 The comments received from the concerned Commissionerate, i.e. Principal Commissioner of Customs (Air Cargo), Chennai-Vll Commissionerate, vide letter dated 08.04.2025, were forwarded to the applicant for their rebuttal. In response, the applicant submitted their rebuttal, vide letter dated 15.04.2025, as detailed below:

i. They must not be excluded by the terms of Note 2 to this Section, and

ii. They must be suitable for use solely or principally with the articles of Chapter 86 to 88 Section, and

iii. They must not be more specifically included elsewhere in the Nomenclature Section.

(e) machines and apparatus of headings 8401 to 8479, or parts thereof other than the radiators for the articles of this Section, articles of heading 8481 or 8482 or, provided they constitute integral parts of engines and motors, articles of heading 8483.

Further CMC and CSC as hydraulic cylinders are covered under CTH 8412, which is also not in dispute. Therefore, conditions (a) and (c) above are clearly not satisfied. From the assertion of the Commissioner, it could be seen that he is not very convinced about satisfaction of two of the conditions as he states that, 'they appear to be meeting the other 2 criteria as well.

2. The expressions "parts" and "parts and accessories" do not apply to the following articles, whether or not they are identifiable as for the goods of this Section:

"(H) Brakes (shoe, segment, disc, etc.) and parts thereof (plates, drums, cylinders, mounted linings, oil reservoirs for hydraulic brakes, etc.): servo brakes and parts thereof "

"(C) Clutches (cone, plate, hydraulic, automatic, etc., but net the electromagnetic clutches of heading 85.05), clutch casings, plates and levers, and mounted linings ".

6. Details of Hearing

6.1 A hearing was held on 13.06.2025 at 03.30 PM. Sh. P. Sridharan, authorized representative appeared online for the hearing on behalf of the applicant and reiterated the contention submitted with the application. He stated that the subject goods, namely Clutch Master Cylinder (CMC) and Clutch Slave Cylinder (CSC), are used in the clutch systems of motor vehicles and are classifiable under CTH 8412, specifically under CTI 8412 21 00 as linear acting cylinders. In support of this classification, he referred to Section Note 2(e) of Section XVII, arguing that the subject goods are excluded from the ambit of Section XVII, thereby ruling out classification under CTH 8708. He further relied on the following case laws and rulings: (i) CCE Delhi Vs Uni Products India Limited (ii) CBIC Instruction No. 01/2022 arising out of Hon'ble SC decision in the case of Ms. Westinghouse Saxby Farmer Ltd. v. CCE, Calcutta (iii) Intel Design Systems (India) P. Ltd. v. CCE, 2008 (223) ELT 135 (SC.) (iv) German Ruling DEBTI 51081/21-1 dated 03/02/2022 (v) France Ruling FRBTIFR-BTI-2022-03884 dated 01/07/2022

With respect to confidentiality of the ruling, it was stated that the matter would be examined in terms of potential trade secrets, copyright concerns, and other relevant factors, and an appropriate decision would be taken accordingly.

    Nobody appeared on behalf of the department for the hearing.

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 submission made by the applicant, response received from the concerned commissionerate, the arguments presented during the hearing, and the rebuttal filed 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 products i.e., Clutch Master Cylinder (CMC) and Concentric Slave Cylinder (CSC) are classifiable under CTH 8412 as a Linear Acting (Cylinders), or under CTH 8708 as parts of motor vehicle of heading 8701 to 8705, of the First Schedule of the Customs Tariff Act, 1975.

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 has submitted that the Clutch Master Cylinder (CMC) and Concentric Slave Cylinder (CSC) are essential components of a motor vehicle's hydraulic clutch system. While differing in appearance, both serve integrated functions within the system.

The CMC is used in semi-hydraulic and fully hydraulic clutch systems to transmit pedal movement to the clutch via hydraulic fluid. It comprises a body (made of aluminium or plastic), an anodized aluminium piston, primary and secondary seals, a push rod, and both low-pressure and high-pressure nozzles. The primary seal isolates the reservoir from the hydraulic chamber, while the secondary seal isolates the reservoir chamber from the external environment. The push rod connects to the clutch pedal, and the nozzles connect to the reservoir and high-pressure lines. The CMC is connected to a fluid reservoir, sometimes shared with the brake master cylinder, and functions as a transmitter of driver input to the clutch.

The CSC is a hydraulic cylinder with an integrated release bearing, eliminating the need for a clutch fork and conventional release bearing. Mounted concentrically on the gearbox input shaft, it is made of lightweight aluminium and is in direct contact with the clutch cover diaphragm, enhancing system efficiency. The CSC simplifies the mechanism and improves the smooth operation of the clutch.

7.6 Now. I take up the matter requiring the ruling on the classification of the product i.e., Clutch Master
Cylinder (CMC) and Concentric Slave Cylinder (CSC) under CTH 8412 as Linear Acting (Cylinder) as
proposed by the applicant.

7.6.1 The applicant submitted that the clutch pedal is linked directly to the piston of the master cylinder. When the driver pushes the clutch pedal, the piston moves within the master cylinder and compresses the hydraulic fluid building up pressure. The pressure is transmitted through the high-pressure pipe to the slave cylinder. The pushrod is connected to the piston of the salve cylinder. Due to the increase of pressure in the slave cylinder, the pushrod is pushed outside acting on the clutch fork, which releases the pressure plate and opens the clutch. The hydraulic fluid used for actuation is usually brake fluid or mineral oil. Their operation depends on the hydraulic pressure created by the hydraulic fluid. Based on their function, as discussed above, both the CMS and CSC are the essentially linear acting hydraulic cylinders as covered under the category of (B) HYDRAULIC POWER ENGINES AND MOTORS as per HSN Explanatory Notes to CTH 8412 (Other engines and motors).

In this regard, I note that the Chapter Heading 8412 covers "Other engines and motors''. The relevant Explanatory Note to CTH 8412 provides that,

"8412.10 - Reaction engines other than turbo-jets
              - Hydraulic power engines and motors:
8412.21 — Linear acting (cylinders)
8412.29 - Other
              - Pneumatic power engines and motors:
8412.31 —Linear acting (cylinders)
8412.39 -Other
8412.80-Other
8412.90 -Parts

This heading covers engines and motors not included in the preceding headings (headings 84.06 to 84.08, 84.10 or 84.11) or in heading 85.01 or 85.02. It therefore covers non-electric engines and motors other than steam turbines and other vapour turbines, spark ignition and compression-ignition internal combustion piston engines, hydraulic turbines, water wheels, turbo-jets, turbo-propellers or other gas turbines.

The heading includes reaction engines (other than turbo-jets), pneumatic power engines and motors, wind engines (windmills), spring-operated or weight-operated motors, etc., certain hydraulic power engines and motors, and certain steam or other vapour power units.

(A) REACTION ENGINES OTHER THAN TURBO-JETS

(B) HYDRAULIC POWER ENGINES AND MOTORS

This group includes:

(1) Certain engines, other than turbines or wheels of heading 84.10, producing mechanical power by utilising the energy' of the waves or sea swell (Savonius rotor with two semicylindrical bladings) or of the tides.

(2) Water column machines operating by the pressure of water on pistons. The water acts on two or more pistons moving inside the (cylinders which in turn drive a shaft.

(3) Hydraulic cylinders consisting, for example, of a brass or steel barrel and a piston operated by oil (or other liquid) under pressure applied on one side (single-acting) or on both sides (double-acting) of the piston, the energy of the liquid under pressure being converted into a linear motion. These cylinders are used on machine-tools, construction machines, steering mechanisms, etc.

(4) Hydraulic valve actuators, presented separately, consisting of a metal casing containing a piston which, by means of a pin perpendicular to the piston rod, converts the linear motion caused by the action of a liquid under pressure into a rotary motion, in order to operate a plug valve or other appliance with a rotating mechanism.

(5) Hydraulic servomotors which perform the role of final or intermediate actuators in feedback control systems or regulating systems. These servomotors are used, e.g., in aircraft.

(6) Hydraulic systems consisting of a hydraulic power unit (comprising essentially a hydraulic pump, an electric motor, control valves and an oil tank), hydraulic cylinders and the pipes or hoses needed to connect the cylinders to the hydraulic power unit, the whole forming a functional unit within the meaning of Note 4 to Section XVI (see the General Explanatory Note to that Section). These systems are used, e.g., to operate civil engineering structures."

From the above, it is evident that a hydraulic cylinder is a linear actuator that converts hydraulic energy (fluid pressure) into linear mechanical force and motion. It typically consists of:

7.6.2 In the present case, the Clutch Master Cylinder (CMC), based on its function as discussed, does not perform this conversion. Instead, it converts mechanical input from the clutch pedal into hydraulic pressure, which is then transmitted via a pressure pipe to the slave cylinder to engage or disengage the clutch.

The CMC does not generate mechanical power or produce linear motion from hydraulic energy. Rather, it functions as a hydraulic pressure generator, not an actuator. It simply creates and transmits hydraulic pressure.

Accordingly, since the Clutch Master Cylinder does not convert fluid pressure into motion, it does not fulfil the essential characteristics of a hydraulic cylinder as defined under the category of (B) Hydraulic Power Engines and Motors in the HSN Explanatory Notes to CTH 8412 (Other engines and motors). Therefore, it does not merit classification under CTH 8412.

7.6.3 In the present case, the Concentric Slave Cylinder (CSC), is a hydraulic component in a clutch system that combines the functions of a slave cylinder and release bearing into a single unit, mounted concentrically around the gearbox input shaft. The concentric slave cylinder combines the slave cylinder and mechanical clutch release bearing functions, and consists of:

A concentric Slave Cylinder has a concentric (circular) design, is mounted around the transmission input shaft, and incorporates the release bearing. In a CSC system, the release bearing is integrated with the hydraulic piston and plays a critical role in clutch operation by directly contacting the clutch diaphragm spring. When the driver presses the clutch pedal, hydraulic pressure moves the piston, and thus the release bearing forward to push against the diaphragm spring, thereby disengaging the clutch and separating the engine from the transmission. When the pedal is released, the diaphragm spring pushes the bearing and piston back, re-engaging the clutch. This integrated design ensures a compact, efficient, and smooth clutch actuation, eliminating the need for a separate clutch fork and release bearing.

The release bearing in a CSC is essential, as it physically contacts the clutch diaphragm spring and transmits hydraulic force from the piston to disengage the clutch. Without it, the CSC would not be able to actuate the clutch, and the clutch would not release. Therefore, it is evident that the CSC comprises both a hydraulic cylinder and a release bearing, facilitating the smooth operation of the clutch system.

A concentric slave cylinder (CSC) with an integrated release bearing is a component of the clutch system. It is a hydraulic clutch component that combines the functions of both the slave cylinder and the release bearing into a single unit. The CSC is part of the vehicle's transmission system and is responsible for engaging and disengaging the clutch. It forms an integral part of the hydraulic clutch system, which also includes the master cylinder, pressure pipe, and other components. The concentric slave cylinder integrates the hydraulic cylinder and the release bearing into one unit, effectively making it a single component.

Although the CSC contains a hydraulic cylinder, it also incorporates a release bearing specifically designed for clutch actuation in vehicles. The release bearing's design enables it to rotate with the diaphragm spring, ensuring smooth and frictionless operation. Its integration into the CSC housing simplifies the system by eliminating the need for a separate release bearing, thereby improving reliability and reducing maintenance requirements. As such, it performs a function that extends beyond that of a standard hydraulic cylinder as described in the HSN Explanatory Notes to Heading 8412. Consequently, the CSC cannot lie classified as Linear acting hydraulic cylinder under Heading 8412.

7.6.4 In view of the above, it is also evident that the Clutch Master Cylinder (CMC) does not convert fluid pressure into mechanical motion; rather, it converts mechanical input (from the clutch pedal) into hydraulic pressure. As such, it does not fulfill the essential characteristics of a "hydraulic cylinder" as provided in the HSN Explanatory Notes to Heading 84.12. Therefore, the CMC does not merit classification under Heading 8412.

Furthermore, a concentric slave cylinder (CSC) not only uses hydraulic pressure to produce linear motion but also integrates a release bearing. This release bearing rotates with the diaphragm spring of the clutch and is specifically designed to disengage the clutch. Consequently, the CSC performs a function that goes beyond that of a standard hydraulic cylinder as described in the HSN Explanatory Notes to Heading 8412. Therefore, the CSC cannot be classified as a linear acting hydraulic cylinder under Heading 8412.

7.7 Let me examine the issue of classification of the product i.e. Clutch Master Cylinder (CMC) and Concentric Slave Cylinder (CSC), under CTH 8708 as parts of motor vehicles.

7.7.1 The applicant has submitted that the Clutch Master Cylinders (CMC) and Concentric Slave Cylinder (CSC), are used in the clutch systems of motor vehicles, specifically in semi-hydraulic and fully hydraulic clutch configurations. The CMC and CSC are key components in the clutch actuation mechanism and are designed exclusively for use in motor vehicles. Given that the CMC and CSC are specifically engineered for and used in motor vehicle clutch systems, and are identifiable as a part of such vehicles, it is necessary to examine the classification of the subject goods under Customs Tariff Heading (CTH) 8708, which covers parts and accessories of motor vehicles, under the Customs Tariff Act.

7.7.2 Chapter 87 is covered under Section XVII (vehicles, aircraft, vessels and associated transport equipment). Classification of parts and accessories of motor vehicle is governed by Section Note 2 of Section XVII and same as mentioned below:

2. The expressions- "parts" and "parts and accessories" do not apply to the following articles, whether or not they are identifiable as for the goods of this Section:

(a) joints, washers or the like of any material (classified according to their constituent material or in heading 8484) or other articles of vulcanised rubber other than hard rubber (heading 4016);

(b) parts of general use, as defined in Note 2 to Section XV, of base metal (Section XV), or similar goods of plastics (Chapter 39);

(c) articles of Chapter 82 (tools);

(d) articles of heading 8306;

(e) machines and apparatus of headings 8401 to 8479, or parts thereof other than the radiators for the articles of this Section, articles of heading 8481 or 8482 or, provided they constitute integral parts of engines and motors, articles of heading 8483;

(f) electrical machinery or equipment (Chapter 85);

(g) articles of Chapter 90;

(h) articles of Chapter 91; (ij) arms (Chapter 93);

(k) luminaries and lighting fittings and parts thereof heading 9405; or

(I) brushes of a kind used as parts of vehicles (heading 9603).

7.7.3 Thus, Section Note 2 of Section XVII restricts the application of the expression "parts" and "parts and accessories" by excluding certain articles from being classified under the chapter 87 of this Section. The applicant has contended that, in accordance with Note 2(e) to Section XVII of the Customs Tariff, machines and apparatus falling under headings 8401 to 8479, or parts thereof, are not to be classified as parts or accessories of motor vehicles, even if they are identifiable as being suitable for use with such vehicles. The applicant argues that, as the Clutch Master Cylinders (CMC) and Concentric Slave Cylinder (CSC) in question are essentially linear acting hydraulic cylinders, they fall specifically under CTH 8412 21 00 by application of General Interpretative Rule (GIR) 1. Therefore, even assuming that the CMC and CSC are identifiable as being used solely or principally with motor vehicles, their classification under CTH 8708 as parts of motor vehicles is excluded by virtue of Note 2(e) to Section XVII.

However, as discussed at para 7.6.2, the Clutch Master Cylinder does not convert fluid pressure into motion and therefore does not exhibit the essential characteristics of a hydraulic cylinder as defined under the category of (B) Hydraulic Power Engines and Motors in the HSN Explanatory Notes to CTH 8412 (Other engines and motors). Consequently, it does not merit classification under CTH 8412.

Further, as discussed at para 7.6.3, Concentric Slave Cylinder (CSC) contains a hydraulic cylinder, it also incorporates a release bearing specifically designed for clutch actuation in vehicles. The release bearing's design enables it to rotate with the diaphragm spring, ensuring smooth and frictionless operation. Its integration into the CSC housing simplifies the system by eliminating the need for a separate release bearing, thereby improving reliability and reducing maintenance requirements. As such, it performs a function that extends beyond that of a standard hydraulic cylinder as described in the HSN Explanatory Notes to Heading 8412.

Accordingly, both the CMC and CSC do not fall within the scope of Heading 8412 and are not excluded from classification under Section XVII by Note 2(e), as claimed by the applicant.

Furthermore, the Clutch Master Cylinders (CMC) and Concentric Slave Cylinder (CSC), do not fall under any of the other exclusion categories listed under Section Note 2 of Section XVII. Therefore, they qualify for classification under Chapter 87.

7.7.4 The HSN Explanatory Notes to Section XVII further amplifies the scope and ambit of the Section Notes. Part III deals with Parts and accessories. The same is reproduced below for ease of reference:

(III) PARTS AND ACCESSORIES

''........The other Chapters of this Section each provide for the classification of parts and accessories of the vehicles, aircraft or equipment concerned. It should, however, be noted that these headings apply only to those parts or accessories which comply with all three of the following conditions:

(a) They must not be excluded by the terms of Note 2 to this Section and

(b) They must be suitable for use solely or principally with the articles of Chapters 86 to 88 and

(c) They must not be specifically included elsewhere in the Nomenclature.

The above provisions show that for any item to be classified as a part and accessories in Chapter 87, all the three conditions as at (a), (b) and (c) above have to be fulfilled cumulatively.

7.7.5 1 have gone through the list of 'parts and accessories' excluded as per the provisions of the Explanatory Notes 2 to Section XVII and found that 'Clutch Master Cylinders (CMC) and Concentric Slave Cylinder (CSC)' are not listed among the excluded items, thereby satisfying the first condition. Furthermore, based on the applicant's submission, it is clear that the Clutch Master Cylinders (CMC) and Concentric Slave Cylinder (CSC), by its configuration, specific functions, and intended use, are designed for exclusive or principal use in motor vehicles. These vehicles are classified under headings 87.03 and 87.11 of Chapter 87 of the First Schedule to the Customs Tariff Act, 1975, thereby meeting the second condition. Additionally, these products are not specifically classified under any other heading in the Tariff, thereby satisfying the third condition also.

Since all the three conditions have been satisfied, it can be concluded that the 'Clutch Master Cylinders (CMC) and Concentric Slave Cylinder (CSC)' qualify as parts of motor vehicle under Chapter 87 in accordance with the Rule 1 of GIR, Section XVII and Chapter Notes of Customs Tariff Act, 1975.

7.7.6 The Heading 8708 falls under Section XVII of HSN covers 'Parts and accessories of Motor vehicles of Heading 8701 to 8705'. The relevant entries and HSN Explanatory Notes to CTH 8708 are reproduced hereunder:

8708             Parts and Accessories of the Motor vehicles of Heading 8701 to 8705

8708 10             -Bumpers and parts thereof:

8708 10 10     —For tractors

8708 10 90     —Other

                        - Other parts and accessories of bodies
                        (including cabs)

8708 21 00         -Safety seat belts

8708 22 00     — Front windscreens (windshield), rear windows and other windows specified in
                        Sub-Heading Note 1 to this chapter

8708 29 00         - Other

8708 30 00         —Brakes and servo-brakes; parts thereof

8708 40 00         - Gear boxes and parts thereof

8708 50 00         - Drive-axles with differential, whether or not provided with other transmission
                            component, non-driving axles; parts thereof

8708 70 00         - Road wheels and parts and accessories thereof

8708 80 00         - Suspension systems and parts thereof
                        -Other parts and accessories:

8708 91 00         - Radiators and parts thereof

8708 92 00         —Silencers and exhaust pipes; parts thereof

8708 93 00         - Clutches and parts thereof

8708 94 00         — Steering wheels, steering columns and steering boxes; parts thereof

8708 95 00         - Safety airbags with inflaters system; parts thereof

8708 99 00         - Other

"Parts and accessories of this heading include:

(A) Assembled motor vehicle chassis-frames (whether or not fitted with wheels but without engines) and parts thereof (side-members, braces, cross-members; suspension mountings; supports and brackets for the coachwork, engine, running-boards, battery or fuel tanks, etc.).

(B) Paris of bodies and associated accessories, for example, floor boards, sides, front or rear panels, luggage compartments, etc.; doors and parts thereof bonnets (hoods); framed windows, windows equipped with heating resistors and electrical connectors, window frames; running-boards; wings (fenders), mudguards; dashboards; radiator cowlings; number-plate brackets; bumpers and over-riders; steering column brackets; exterior luggage racks; visors; non-electric heating and defrosting appliances which use the heat produced by the engine of the vehicle; safety seat belts designed to be permanently fixed into motor vehicles for the protection of persons; floor mats (other than of textile material or unhardened vulcanised rubber), etc. Assemblies (including unit construction chassis-bodies) not yet having the character of incomplete bodies, e.g., not yet fitted with doors, wings (fenders), bonnets (hoods) and rear compartment covers, etc., are classified in this heading and not in heading 87.07.

(C) Clutches (cone, plate, hydraulic, automatic, etc., hut not the electro-magnetic clutches of heading 85.05), clutch casings, plates and levers, and mounted linings.

(D) Gear boxes (transmissions) of all types (mechanical, overdrive, preselector, electro-mechanical, automatic, etc.), torque converters; gear box (transmission) casings; shafts (other than internal parts of engines or motors); gear pinions, direct-drive dog-clutches and selector rods, etc "

7.7.7 The applicant has submitted that the Clutch Master Cylinder (CMC) and Concentric Slave Cylinder (CSC) are integral components of the hydraulic clutch system of a motor vehicle and, as such, constitute a part of that system. As per the HSN Explanatory Notes discussed above, heading 8708 explicitly covers clutches and parts thereof, including hydraulic clutches and their components, except for electro-magnetic clutches (classified under Heading 85.05). In the present case, both the CMC and CSC are essential parts of the hydraulic clutch system, and this fact has also been duly acknowledged by the applicant. It is nobody's case that Clutch Master Cylinder (CMC) and Concentric Slave Cylinder (CSC) are not the essential part of the clutch system of a motor vehicle.

Customs Tariff Item (CTI) 87089300 of the Customs Tariff covers "clutches and parts thereof''. Since the subject goods form an integral part of the hydraulic clutch system of a motor vehicle, hydraulic clutch systems and their integral components, such as the CMC and CSC, fall within the scope of Heading 8708. Accordingly, the subject goods namely Clutch Master Cylinder (CMC) and Concentric Slave Cylinder (CSC) are appropriately classifiable under Customs Tariff Item (CTI) 8708 93 00 (Clutches and parts thereof), in accordance with General Interpretative Rule (GIR) 1, Section XVII, and the Explanatory Notes to Heading 8708 of the Customs Tariff Act, 1975.

7.8 The Applicant has contended that the subject goods cannot be classified under CTH 8708 solely on the ground that they are identifiable for use exclusively or principally with motor vehicles. In support of this argument, they relied on the judgment of the Hon'ble Supreme Court in CCE, Delhi v. Uni Products Ltd. -2020 (372) E.L.T. 465 (S.C.), wherein the Court emphasized that all three conditions stipulated for classification under the chapters of Section XVII must be satisfied. They further cited the decision in Intel Design Systems (India) P. Ltd. v. CCE, 2008 (223) E.L.T. 135 (S.C.), and CBIC Instruction No. 01/2022, which was issued following the Hon'ble Supreme Court's decision in M/s. Westinghouse Saxby Farmer Ltd. v. CCE, Calcutta. The said instruction advises that the classification of automobile parts must be determined based on a holistic assessment, including the HS Explanatory Notes, relevant Section and Chapter Notes, and applicable judicial decisions.

In this context, it is submitted that the classification of the product, i.e.. Clutch Master Cylinder (CMC) and Clutch Slave Cylinder (CSC), under CTH 8708 has been considered after evaluating the relevant Chapter Notes, Section Notes, the three conditions outlined in Part III of the General Explanatory Note to Section XVII, the exclusionary clause under Note 2 to Section XVII, and the Explanatory Notes to Chapter 87.

Additionally, I observe that that Hon'ble Supreme Court in the case of Commissioner of Central Excise Vs. Wockhardt Life Sciences Ltd reported in 2012 (277) ELT 299 (SC) had held that the functional utility and predominant usage of the commodity must be taken into account apart from the understanding in common parlance to determine the correct classification of the product. The Hon'ble Supreme Court in the case of Collector of Customs Vs. Kumudam Publications [1997 (96) ELT 226 (SC)] has held that "it is not entirely correct to say that the end use or function of the goods is irrelevant to decide the question of classification". A three Judge Bench of the Hon'ble Supreme Court had also relied upon the function and end use in determining the classification in the case of Indian Tool Manufactures Vs. Asst. Collector of Central Excise, Nasik & Others reported in 1994 (74) ELT 12 (SC). Similarly, the Hon'ble Supreme Court in the matter of O.K. Play (India) Ltd. Vs CCE, Delhi [2005(180) ELT (300) (S.C.)] has laid down following three parameters for the classification of the goods: (i) HSN along with explanatory notes which provide a safe guide for interpretation of an entry, (ii) equal importance to be given to Rule of Interpretation of Tariff, (iii) Functional utility, design, shape and predominant usage have also got to be taken into account while determining classification of an item. Therefore, while end use alone may not be decisive for classification, it remains a relevant factor that should be considered along with other statutory criteria when determining the appropriate classification of goods.

7.9 The applicant has relied upon the American Customs Ruling No HQ HI95876 dated March 24, 2016 wherein they approved the classification of the CMC under CTH 8413 5000 as a reciprocating positive displacement pump, while approving the classification of CSC under CTH 8412 2100 and ruled out classification of CMC and CSC under CTH 8708. Further, the applicant has submitted that classification for CMC under CTH 84135000 as reciprocating positive displacement pump, may not be correct as the definition of pumps under the Harmonized System Nomenclature (HSN) Explanatory Notes to Heading 8413 requires the device to raise or otherwise continuously displace volumes of liquid. In the case of the CMC, there is no such continuous action.

The Applicant has also relied upon German Ruling DEBT151081/21-1 dated 03/02/2022 and French Ruling FRBTIFR-BTI-2022-03884 dated 01/07/2022, where Clutch Master Cylinder was classified under CTH 8412.

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. Furthermore, since the applicant themselves have acknowledged that the classification of the CMC under CTH 8413 50 00, as per the aforementioned U.S. ruling, may not be correct, the reliance placed on these foreign rulings does not hold relevance or persuasive value in determining the appropriate classification under the Indian Customs Tariff.

8. The jurisdictional Commissionerate has argued that the CMC and CSC meet the criteria for classification under Section XVII as they are not excluded under Note 2, are solely or principally used with motor vehicles, and are not more specifically included elsewhere. The Commissionerate also noted that reliance on foreign rulings is not appropriate, given that classification decisions must be case-specific, and Supreme Court decisions emphasize that each case depends on its own facts. Therefore, the goods are correctly classified under CTI 8708 9300 as "Clutches and parts thereof instead of CTI 8412 2100.

I concurred with the view expressed by the concerned jurisdictional Commissionerate regarding the classification of CMS and CSC as parts of the clutch system of motor vehicles under CTI 8708 9300 (Clutches and parts thereof).

9. The applicant, in their submission, has requested that the ruling and related information not be published, citing the highly technical nature of the data provided in the application. It has been contended that the application contains proprietary technical details that are unique to the applicant and critical to their competitive position and that disclosure of such information could potentially result in an unfair advantage to
competitors.

The Authority has duly considered the request in light of Regulation 27 of the Customs Authority for Advance Rulings Regulations, 2021, as amended vide Notification No. 63/2022-Customs (N.T.) dated 20.07.2022, which provides that:

"27. Publication of orders or advance rulings - Such of the orders or advance ridings of the Authority, as the Authority deems fit for publication in any authoritative report or the press, may be released for such publication on such terms and conditions as the Authority may specify.

Provided that at the request of the applicant, the Authority may take necessary steps in order to protect commercially confidential information ".

Upon examination, it is observed that the ruling in the present case does not contain any technical data or proprietary information that is unique to the applicant. Furthermore, the details of the products in question are publicly available, and the information submitted by the applicant appears to have been sourced from websites accessible in the public domain, including the applicant's own website

Accordingly, I am of the view that the request for confidentiality does not warrant consideration in the present case, as the ruling does not reveal any sensitive or commercially confidential information requiring protection under Regulation 27. Therefore, the request to keep the ruling confidential is not accepted.

10. On the basis of foregoing discussions and findings, I reach to conclusion that the products under question namely, Clutch Master Cylinder (CMC) and Concentric Slave Cylinder (CSC) merit classification under CTH 8708 (Parts and Accessories of the Motor vehicles of Heading 8701 lo 8705), more specifically under CTI 87089300 (Clutches and parts thereof) of the First Schedule of the Customs Tariff Act, 1975.

11. I rule accordingly.

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

F. No. CAAR/CUS/APPL/32/2025-O/o Commr-CAAR-Mumbai                 Dated: 20-06-2025

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

1. M/s. Valeo India Private Limited
CEE DEEYES IT Park, Block No. I,
No.63, Rajiv Gandhi Salai, Navalur.
Chennai-600 130.
{Email: dinesh-raja.r@valeo.com}

2. The 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-1, Ballard Estate,
Mumbai -400001.
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: anishgupta.irs@gov.in, commr.legal-cbec@nic.in

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

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

8. Guard file.

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