Madras HC Sets Aside Air and Oil Filter Classification Orders for Ignoring HSN Triple Test

Inzi Controls India Limited Vs Joint Commissioner (Madras High Court)

Summary: The Madras High Court set aside the appellate orders rejecting Inzi Controls India Limited’s challenge concerning classification of air and oil filters and remanded the matters to the appellate authority for fresh consideration. The petitioner, a manufacturer supplying filters to automobile companies, classified the goods under Chapter 84, specifically tariff headings 8421 23 00 and 8421 31 00, whereas the department sought classification under Chapter 87. The petitioner contended that the HSN Explanatory Notes prescribe a cumulative triple test for classification of parts under Section XVII and that its products failed two of those conditions because machines and apparatus falling under headings 8401 to 8479 are excluded by Note 2(e) and the goods are specifically covered under heading 8421. Reliance was placed on Supreme Court decisions including CCE v. Uni Products Ltd. and on CBIC Instruction No.1/2022-Cus dated 05.01.2022. The High Court did not decide the classification dispute on merits. It examined whether the decision-making process suffered from a deficiency warranting judicial review despite availability of an appellate remedy. The Court found that the appellate authority did not engage with the petitioner’s principal contention concerning the cumulative triple test and instead relied strongly on the “sole or principal use test”, Westinghouse Saxby and Hanon Automotive Systems. It also failed to consider the judgments relied upon by the petitioner and CBIC Instruction No.1. Holding that this constituted a flaw in the decision-making process, the Court set aside the appellate orders and directed reconsideration after reasonable opportunity to the petitioner, with fresh orders to be passed within six months.