In re Manuel Steel Decor (CAAR Mumbai)
An application for advance ruling was filed before the Customs Authority for Advance Rulings, Mumbai, by an importer proposing to commence import and sale of “Architectural Decorative Designer Wall Panel Articles of Stainless Steel” of different shapes, sizes, and finishes, with or without drilled holes in the corners. The application was received on 03.10.2025 under Section 28-I(1) of the Customs Act, 1962. The applicant sought clarification on the correct tariff classification of the proposed imports, suggesting classification either under Customs Tariff Heading 7308 90 90 (structures and parts of structures) or 7326 90 60 (other articles of stainless steel).
The applicant explained that the goods are fully manufactured, dimensioned, surface-finished stainless steel panels, including finishes such as mirror polish, hairline, satin, embossing, etching, sand blasting, PVD coating, and anti-fingerprint coatings, with protective PVC films. These panels are intended for permanent architectural, structural, and decorative applications such as façade cladding, wall panelling, roofing systems, ceilings, partitions, pillars, elevator interiors, and transportation infrastructure. According to the applicant, depending on use and presence of mounting holes, the panels could be considered either parts of structures or independent finished stainless steel articles.
The applicant relied on the World Customs Organization Harmonized System Explanatory Notes, arguing that the goods were “further worked” finished products and not raw materials. It was also submitted that identical goods had been cleared at certain ports under headings 7308 or 7326. No comments were received from the jurisdictional customs commissionerate despite multiple references. During the personal hearing, the applicant reiterated its submissions and emphasized that the panels form an integral and immovable part of the built environment.
