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Power Recliner Is a Motor-Vehicle Seat Part, Classifiable Under CTI 94019900: CAAR

Case Law Details

TaxGuru Citation
2025 taxguru.in 11700
Case Name
In re Adient India Private Limited (CAAR Mumbai)
Date of Judgement/Order
Only available for paid members
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In re Adient India Private Limited (CAAR Mumbai)

M/s Adient India Private Limited filed an application before the Customs Authority for Advance Rulings (CAAR), Mumbai seeking an advance ruling on the classification of “Power Recliner” imported for use in motor vehicle seats. The application, received on 20.08.2025, concerned whether the product should be classified as a part of motor vehicles under Heading 8708 or as a part of seats under Heading 9401 of the Customs Tariff Act, 1975.

The applicant, a manufacturer and seller of automotive seating systems and components, imports power recliners for use in the assembly of motor vehicle seats. The power recliner is a metal structural component integrated into the backrest of the seat to enable angular adjustment of the seatback through a lever or knob. It forms an internal part of the vehicle seat structure, operates only when incorporated into it, and cannot be fitted elsewhere in a motor vehicle.

The applicant submitted that the power recliner should be classified under Tariff Item 9401 99 00 as “parts of seats”. They referred to the General Rules for Interpretation (GRI), tariff structure, explanatory notes and judicial precedents to support their view. They argued that Heading 9401 provides a specific entry for seats, including motor vehicle seats, and their parts. They also pointed out that Heading 8708 covers general motor vehicle parts but excludes items more specifically classified elsewhere, including vehicle seats, per Section XVII notes.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,985

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