Mitsubishi Electric Automotive India Pvt. Ltd. Vs Commissioner of Customs (CESTAT Delhi)
The Delhi Bench of the CESTAT disposed of seventeen appeals involving the classification of Electronic Control Units for Electronic Power Steering (EPS-ECU) and their parts imported by the appellant during the period April 2025 to July 2025. The appellant had classified the imported goods under CTH 8708 94 00/8504 5090, while subsequently contending that the correct classification should be under CTH 8537, 8543, or 9032. Differential customs duty was paid under protest, and the appeals challenged the assessment orders.
The Tribunal noted that the issue had already been decided in the appellant’s own case through an earlier final order concerning identical goods. That earlier decision had held that EPS-ECU is a part of the automobile power steering system and not an instrument or apparatus falling under Chapter 90, an electrical control board under CTH 8537, or an electrical machine having an individual function under CTH 8543. It had also held that the parts of EPS-ECU could not be classified under the alternative tariff headings claimed by the appellant once the principal item itself was found to be classifiable under CTH 8708 94 00.
The appellant relied upon subsequent decisions of the Chennai Bench in Hyundai Motors Ltd. and Mobis India Ltd., where certain ECUs had been classified under CTH 9032. The Tribunal examined those decisions and observed that the Chennai Bench had distinguished the earlier Delhi Bench decision on facts, holding that ECU is a generic term and that each ECU must be classified on its own merits. The Tribunal found that the EPS-ECU involved in the present appeals was identical to the EPS-ECU considered in the appellant’s earlier case, and therefore the previous Delhi Bench decision continued to govern the issue. It also noted that although the earlier order had been challenged before the Supreme Court, no stay had been granted, and the earlier decision continued to hold the field.
