In re MACFOS Limited (CAAR Mumbai)

The applicant sought an advance ruling on the customs classification of two products proposed to be imported: the Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board) and the Espressif ESP32-C3-WROOM-02-N4 Module. The applicant proposed classification of the development board under Customs Tariff Item (CTI) 84719000 as an automatic data processing (ADP) machine and the module under CTI 84733010 as a part of an ADP machine.

The applicant explained that it operates an e-commerce platform dealing in electronic components, robotic parts, DIY kits, 3D printing, prototyping, and assembly services. It contended that the development board is a programmable microcontroller board intended for learning, prototyping, embedded systems, robotics, industrial automation, and Internet of Things (IoT) applications. According to the applicant, the board contains a processor, memory, programmable interfaces, Wi-Fi and Bluetooth connectivity, and can collect, process, control, and transmit data automatically. The applicant emphasized that it is a general-purpose programmable board rather than a finished consumer product and that software programming for a specific application occurs only after import.

The applicant relied upon the General Rules for Interpretation (GIR), Chapter Notes to Chapter 84, and the principle that a specific tariff entry prevails over a general one. It argued that the development board satisfies the conditions prescribed in Chapter Note 5(A) for automatic data processing machines because it can store programs, be freely programmed, perform arithmetic operations, and execute programs without human intervention. The applicant also argued that the product does not perform a specific function within the meaning of Chapter Note 5(E) and therefore should be classified under Heading 8471, specifically CTI 84719000. It further submitted that Heading 8542 was not applicable because the product consisted of components mounted on a printed circuit board.

Regarding the ESP32-C3-WROOM-02-N4 Module, the applicant submitted that it is a compact IoT module built around the ESP32-C3 System-on-Chip with a 32-bit RISC-V processor, integrated Wi-Fi, Bluetooth, flash memory, peripherals, and an antenna. It argued that the module forms part of the development board, is solely and principally used with an ADP machine covered under Heading 8471, and therefore should be classified under Heading 8473 as a part of such a machine, specifically under CTI 84733010.

In additional submissions, the applicant stated that the primary function of both products is data processing and control, while Wi-Fi and Bluetooth are secondary functions that may be enabled or disabled through software. It reiterated that the development board is a programmable data processing machine imported without housing or input/output devices and that classification should be determined based on the condition of the goods at the time of import. The applicant also maintained that the module is principally used with the development board and should therefore be classified under Heading 8473.

The jurisdictional Customs Commissionerate disagreed with the proposed classification. It observed that the development board functions as an embedded programmable controller intended for incorporation into other equipment and performs specific control and communication tasks rather than operating as a standalone automatic data processing machine. It also noted the absence of characteristics such as an independent user interface, storage media, and a general computing environment. For the module, the Commissionerate considered its essential character to be derived from the semiconductor microcontroller mounted on a printed circuit board and opined that it merited consideration under Chapter 85, specifically Heading 8542, rather than Chapters 84 or 8473.

During personal hearings, the applicant reiterated that the development board functions like an automatic data processing machine, contains processing, data acquisition, control, and transmission capabilities, and that the module incorporates processing, Wi-Fi, Bluetooth, and flash memory. It also argued that the products are intended for general application development and prototyping rather than specialized telecommunication equipment. The applicant relied upon foreign tariff rulings and maintained that wireless functionality does not alter the primary function of data processing. Subsequently, it also submitted that the goods were correctly classifiable under either Heading 8542 or Headings 8471/8473. A fresh hearing was granted after a change in the Authority, during which the authorised representative revised the earlier stand and requested that it be considered.

The Authority examined the application, written submissions, additional submissions, technical literature, personal hearing submissions, the Customs Tariff Act, the General Rules for Interpretation, the relevant Section Notes, Chapter Notes, and the HSN Explanatory Notes. It observed that classification must first be determined under Rule 1 of the GIR by examining the terms of the headings and the relevant notes.

The Authority found that although the development board contains a processor, memory, programmable interfaces, and communication capabilities, it functions as a standalone embedded system designed to control machines, interface with sensors, and execute embedded logic rather than as a conventional automatic data processing machine. It held that the board lacks the essential characteristics of an ADP machine, such as an independent user interface, storage media, and a general-purpose computing environment. It also observed that the product is intended for embedded control applications rather than general-purpose computing.

The Authority further held that the development board is not solely or principally used with automatic data processing machines because it can be used with smart locks, industrial controllers, wearables, sensors, and other devices. Consequently, it did not satisfy the conditions for classification as a part of an ADP system under Chapter Note 6(C). Referring to judicial decisions on the meaning of “part,” the Authority concluded that the development board is not an essential component without which an ADP machine cannot function and therefore cannot be classified under Heading 8473. It also held that Heading 8471 excludes apparatus for the transmission or reception of data and that machines performing functions other than data processing are to be classified according to their respective functions. Accordingly, Headings 8471 and 8473 were held to be inapplicable.

In respect of the ESP32-C3-WROOM-02-N4 Module, the Authority observed that Heading 8473 covers only parts and accessories solely or principally used with machines of Heading 8471. It found that the module is an independent embedded module capable of processing and transmitting data and performing wireless communication functions. Since it has an independent function and performs communication functions through Wi-Fi and Bluetooth, it did not satisfy the conditions for classification as a part under Heading 8473.

The Authority compared ESP32 boards with Arduino boards and noted that ESP32 integrates Wi-Fi and Bluetooth functionality within the same system-on-chip, enabling independent wireless transmission and reception. From the applicant’s own submissions and the manufacturer’s technical literature, the Authority observed that both products integrate wireless communication features as part of their functionality.

After examining the relevant tariff headings and the nature and functions of the goods, the Authority concluded that both the Espressif ESP32-C3-DevKitM-1-N4X Development Board and the Espressif ESP32-C3-WROOM-02-N4 Module are classifiable under Customs Tariff Heading 8517, specifically CTI 8517 62 90 as “Other Communication Apparatus” under the First Schedule to the Customs Tariff Act, 1975. It also accepted the applicant’s request to protect commercially confidential information by keeping the ruling confidential in accordance with the applicable regulations.

FULL TEXT OF THE ORDER OF CUSTOMS AUTHORITY OF ADVANCE RULING, MUMBAI

M/s. MACFOS Limited (IEC . No.: AALCM3S36H) (hereinafter referred to as ‘the Applicant’) filed an application (CAAR-1) for advance ruling in the Office of Secretary, Customs_ Authority.. for Advance _Ruling (CAA.R) Mumbai. The said application was received in the secretariat of the CAAR, Mumbai on 22.12.2025 along with its enclosures in terms of Section 2811 (1) of the Customs Act, 1962 .(hereinafter referred to as the ‘Act als0’). The Applicant is seeking. advance ruling on the issue of classification of “Espressif ESP32-C3 DevKitM-I-N4X. Development Board (Microcontroller Development Board)” and “SOC Product —Espressif_.ESP3_:2-C3-WRQ0M-02-N4 Module”. The applicant intends to import the said goods from the ports of _INCH, than and Air Cargo Complex, .Mumbai.

2. Applicant’s Submissions:

2.1. The applicant is presently operating the c-commerce platform Robu.in, selling a wide range of electronic components, robotic parts, and DIY kits. The company also offers services like 3D printing, prototyping, and ‘assembly. The applicant intends to import two items, i.e., “1,spressif ESP32-C3_:– DevKitM-l-N4X Development Board (Microcontroller Development Board)” and “SOC Product —Espressif ESP32-C3L-WROOM-02-N4 Module”. As per the present scheme. of Classification of Commodities under the Customs Tariff Act, of 1975; “Espressif ESP32-C3-DevKitM-1 -N4X Development Board (Microcontroller Development Board)” is correctly classifiable under Customs Tariff Item 84719000, and “SOC Product — 1:spressif ESP32-C3-WROOM-02-N4 I Module” is correctly classifiable under Customs Tariff Item 84733010.

2.2 The following is the question for which an advance ruling. has been sought by the Applicant:

Whether the “Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board)” proposed to be imported will be classified under the Customs Tariff Item (CTI) 84719000 of the Customs Tariff Act of 1975, and the “SOC Product —Espressif ESP32-C3-WROOM-02-N4 Module” proposed .to _.be imported will be classified under. the Customs Tariff Item (CTI) 847330.10 of the Customs Tariff Act of 1975.

3. The applicant also submitted their important Points to be considered for the Classification of Goods as under:

a) Goods arc classified by taking into consideration the scope of ‘headings/ sub­headings, related Section Notes, Chapter Notes, and the General Interpretative Rules (GIR). The GIR is a set of 6 rules for the classification of goods in the Tariff Schedule. These rules have to be applied sequentially.

b) Interpretative Rules play a very important role in the classification of the goods. Rule 1 of the GIR gives precedence to the Section notes/Chapter notes while classifying a product. Rule 2(a) applies to goods imported in assembled / unassembled condition. Such goods may be incomplete or finished form Rule 2(b) is applicable to ‘mixtures’ and ‘composite goods. Goods which are not classifiable by application of Rule 2(h), will have to be classified by application of Rule 3. Rule 3 has three sub-rules. Rule 4 states that goods which cannot be classified by application of the preceding rules may be classified under the heading appropriate to the goods to which they are most akin. Rule 5 applies to packing materials/articles in which the goods are carried. Rule 6 provides the general guideline for the classification of goods under the appropriate subheading.

c) Any product for which there is no current classification can be listed under the other classification. This term encompasses all products described by the Header and Sub-header of a category.

4. The applicant further submitted that the imported goods “Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board)” are properly and correctly covered under CTI 84719000 for ease of reference is reproduced as below :

a) What is a ‘Microcontroller’?

A microcontroller (MC, uC, or pC) or microcontroller unit (MCU) is a small computer^. on a single integrated circuit. A microcontroller contains one or more processor cores along with memory and programmable input/output peripherals.

Microcontrollers are used in automatically controlled products and devices, such as automobile’ engine control systems, implantable medical devices, remote controls, office machines, appliances, power tools, toys, and other embedded systems. By reducing the size and cost compared to a design that uses a separate microprocessor, memory, and input/output devices, microcontrollers make digital control of more devices and processes practical. Mixed-signal microcontrollers are common, integrating analog components needed to control non-digital electronic systems. In the context of the Internet of Things, microcontrollers arc an economical and popular means of data collection, sensing, and actuating the physical world as edge devices.

• • Embedded design :

A microcontroller can be considered a self-contained system with a processor, memory and peripherals and can be used as an embedded system. The majority of microcontrollers in use today are embedded in other machinery, such as automobiles, telephones, appliances, and peripherals for computer systems. While some embedded systems are very sophisticated. many have minimal requirements for memory and program length, with no operating system, and low software complexity. Typical input and output devices. include switches, relays, solenoids. LEDs, small or custom liquid-crystal displays, radio frequency devices, and sensors for data such. as temperature,. humidity, light level, etc. Embedded systems usually have no keyboard. screen, disks, printers, or other recognizable I/O devices of a personal computer, and may lack human interaction devices of any kind.

b) What is a ‘Microcontroller Development Board’?

A microcontroller development board is a pre-built circuit board featuring microcontroller (like an Arduino or ESP34With essential supporting hardware (memory, Power, I/O pins, USB) to simplify learning, prototyping, and testing embedded systems, saving users from building complex circuits from scratch and accelerating project development for IoT, robotics, arid home automation.

key Components & Features:

• • Microcontroller (MCU): The “brain,” containing CPU, memory (RAM/Flash), and peripherals (timers, ADC). –
  • On-board Peripherals: Built-in LEDs, buttons, sensors, USB ports, serial communication ‘MART; 12C), and^–expansion headers for easy connection.
  • Power Management: Circuits to regulate power from USB or battery,
  • Debugging Tools: Features for in-circuit programming and debugging.

5. The applicant further submitted that the application of `Espressif ESP32-C3- DevKitIVI-l-1;4X Development Board (Microcontroller Development Board)” for ready reference is reproduced below:

The. ESP32 is a microcontroller (MCU) with integrated Wi-Fi and Bluetooth,. not -a simple IC. It is a powerful, versatile chip used in many applications, from low-power sensor networks to more demanding tasks like voice encoding, music streaming, and MP3 decoding. It’s widely used in IoT; mobile devices, and wearable-tech, and is popular with hobbyists for DIY projects and prototyping.

In short:

– ESP32 Small Microcontroller IC Chip.

– it makes electronic devices “smart”.

– commonly used in Robotics, industrial controller and educational kits.

The ESP ’32 is a programmable microprocessor/microcontroller/Sensor, etc., boards. it integrates a high-performance microprocessor core with wireless connectivity ‘features including Wi-Fi and Bluetooth, and is designed for embedded systems, IOT (Internet of Things) devices, &: automation platforms. It combines the features of both a microprocessor (due to its high processing speed, programmable nature, and multitasking capability) and a microcontroller (due to onboard memory, I/O control and peripheral interfaces).

Key applications:

• IoT and smart devices: Its Wi-Fi and Bluetooth capabilities make it ideal for connecting devices to the internet or to each other for home automation, cloud-based security, and other smart projects.
• Educational and -Learning Projects: it is widely used in schools, colleges and technical training programs for teaching embedded systems_; programming, -and IoT concepts.
• Audio and voice applications: With its dual-core processor- and Other integrated components, -it can handle demanding tasks-such-as voice encoding-and-MP3 decoding.
• Prototyping and hobbyist projects: it is ‘a popular ^–choice for beginners and developers to build and-prototype new devices and applications.
• Industrial and low-power applications: Its reliability in a wide temperature range and ability to operate in low-power modes make it suitable for industrial environments and battery- operated devices.

Conclusion:

The ESP 32 module is a compact, versatile, and low-cost, energy-efficient programmable microprocessor board designed for embedded applications. It is widely used globally for developing and manufacturing IOT (Internet of Things) products that require Wi­ll or Bluetooth connectivity. It is important for technological development, prototyping, and R&D purposes, and is wisely used by developers, engineers, and academic institutions. Application range from educational to industrial automation. This module is not a finished consumer product, but a programmable development board intended for integration into systems or for software and educational use.

The applicant also informed that the application of “Espressif ESP32-C3-DevKitM-I- N4X Development Board” is a microcontroller that functions as an automatic data processing Machine. The ESP32 is a microcontroller that functions as an automatic data processing machine. It is designed with a powerful dual-core processor and memory, enabling it to collect, process, and transmit data automatically in various applications, particularly within the Internet of Things (lOT) ecosystem.

(i) How the ESP32 Functions as a Data Processor:

The ESP32 is a System-on-Chip (SoC) that integrates all essential components for computing and communication into a single, low-cost, and low-power package.

• • Processing Unit: At its core, most ESP32 variants feature a dual-core 32-bit Xtensa LX6 microprocessor, capable of operating at speeds up to 240 M1U. This processing power allows it to handle complex tasks and perform real- time data processing; such as running Machine learning algorithmic for object detection or Voice recognition.
  • Data Acquisition: it has a rich set of peripheral interfaces, including General Purpose Input/output (GPIO) pins, Analog-to-Digital Converters (ADCs), and digital communication interfaces (SPI, I2C, UART). These allow it to interface with various sensors (temperature, humidity, motion, etc.) to acquire data from the physical environment automatically.
  • Data Processing & Control: The data collected from sensors is processed by the CPU using programmed logic.. Based on this processing, the ESP32 can make decisions ^–and control other devices (actuators, motors, displays). For instance, a smart thermostat uses the ESP32 to read temperature^– data,. process it against a target temperature, and automatically turn a heating/ cooling system ‘on .or off.
  • Data Transmission: With built-in Wi-Fi and Bluetooth capabilities, the ESP32 can automatically send processed data to cloud services, a smartphone app (like Blink or Firebase), or other connected devices for remote monitoring and analysis. This is a core function in loT applications.

In essence, the ESP32 is a dedicated, programmable machine that processes data automatically based on its programming and inputs, fulfilling the definition of an automatic data processing Machine in the context of embedded-systems and IoT.

(ii) The ESP32-C3-DevKitM-1-N4X isn’t only for’ communication; it’s a versatile microcontroller board for IoT (Internet of Things) projects, combining wireless (Wi- Fi Bluetooth) communication with processing power (RISC-V CPU) to control devices, read sensors, and_, connect to the internet for smart home, wearables, and industrial automation. acting as the, brain for connected “machines” or devices.

Espressif ‘ESP32-C3-DevKitM-l-N4X is excellent for robotics (often called ‘Robotics’ in some contexts), especially for DIY/hobbyist projects, as it’s a budget-friendly microcontroller board with built-in Wi-Fi & Bluetooth (13LE), offering easy connectivity, sensor integration, and remote control for robots using the popular Arduino IDE or ESP-IDE Its GPIO pins allow _,Connecting motors, sensors (ultrasonic, line followers), and actuators, s making it perfect for inert, connected robotic projects like automated carts or drones.

Key Features for Robotics:

• • • go Wireless Connectivity: Wi-Fi & Bluetooth LE for remote control; data logging, and cloud communication.
    • Low-Power RISC-V Core: Efficient processing for various tasks.
    • GPIO Pins: Easily connect sensors (distance, tine tracking) and motor drivers.
    • Arduirio IDE Support: Simple programming for beginners and rapid prototyping
    • USB-to₇IJARI^. Bridge: Easy power and programming via Micro-USB..

Robotics Applications:

• • • Smart Carts: Control movement and^–detect obstacles:
    • Drones/Quadcopters: Remote piloting and .sensor. data.
    • IoT-Enabled Robots: Send sensor data to the cloud for analysis..

(iii) The Espressif ESP32-C3-DevKitM-1-N4X is an entry-level development board designed for industrial automation and IoT. applications. In the context of textile machinery, it is used for real-time monitoring, environmental control, and wireless automation.

Core Capabilities for Textile Machinery.

• • Environmental Monitoring: it is highly effective for controlling temperature and humidity in textile storage and production areas to preserve yarn strength and product quality.
  • Precision Control: Features a 32-bit RISC-V single-core processor (up to 16C)MHz) and peripherals like LED PWM controllers (up to. 6 channels) and TWAI controllers (ISO 11898-1 compatible), which are used for motor speed control and industrial networking.
  • Wireless Integration: Integrated Wi-F Bluetooth. 5.0 (LE) allow machines to communicate wirelessly for remote monitoring or peer-to-peer data exchange via protocols like ESP-NOW.

Photo of “Esprcssif ESP32-C3,DevKitMThN4X Development Board (Microcontroller Development Board)” found on the Website is as below:

7. The extract of the CTH 8471 for ease of reference is reproduced below:

Tariff Item	Description	Unit	Duty
8471	AUTOMATIC DATA PROCESSING MACHINES AND UNITS THEREOF; MAGNETIC OR OPTICAL READERS, MACHINES FOR TRANSCRIBING DATA ON TO DATA MEDIA IN CODED FORM AND MACHINES FOR PROCESSING SUCH DATA, NOT ELSEWHERE SPECIFIED OR INCLUDED
8471 30	Portable automatic data processing machines, weighing not more than 10 kg, consisting of at least a central processing unit, a keyboard and a display:
8471 30 10	Personal computer	u	Free
8471 30 90	Other	u	Free
8471 41	Other automatic data processing machines: Comprising in the same housing at least a central processing unit and an input and output unit, whether or not combined:
8471 41 10	Micro computer	u	Free
8471 41 20	Large or main frame computer	u	Free
8471 41 90	Other	u	Free
8471 49 00	Presented in the form of systems	u	Free
8471 50 00	Processing units other than those of sub-headings 8471 41 or 8471 49, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units	u	Free
8471 60	Input or output units, whether or not containing storage units in the same housing:
8471 60 10	Combined input or output units	u	Free
8471 60 24	Graphic printer	u	Free
8471 60 25	Plotter	u	Free
8471 60 29	Other	u	Free
8471 60 40	Keyboard	u	Free
8471 60 50	Scanners	u	Free
8471 60 60	Mouse	u	Free
8471 60 90	Other	u	Free
8471 70	Storage units:
8471 70 10	Floppy disc drives	u	Free
8471 70 20	Hard disc drives	u	Free
8471 70 30	Removable or exchangeable disc drives	u	Free
8471 70 40	Magnetic tape drives	u	Free
8471 70 50	Cartridge tape drive	u	Free
8471 70 60	CD-ROM drive	u	Free
8471 70 70	Digital video disc drive	u	Free
8471 70 90	Other	u	Free
8471 80 00	Other units of automatic data processing machines	u	Free
8471 70 90	— Other	u	Free

The Chapter note 5(A), (B), (C), (D) & (E) of Chapter 84 for ready reference is reproduced below:

Note – For the proposes of heading 84.71, the expression “automatic data processing machines” means:

(a)^,Digita.1 machines_; capable of (1) storing the processing program or programs and at least the data immediately necessary for the execution of the program; (2) being freely . programmed . in accordance with the requirements of the user; (3) performing arithmetical computations specified by the user; and, (4) executing, without human intervention, a Processing program which requires them. to Modify their execution, by logical decision’ during the processing run;

(b) Analogue machines capable of simulating mathematical models-and comprising at least: analogue elements, control elements, and programming elements;

(c) Hybrid Chines consisting of either a digital machine with analogue clients or an analogue- machine with digital elements.

Note 5 (B)– Automate data processing machines may be in the form of systems consisting of a variable number of separate units. Subject to paragraph (E) below, a until is to be- regarded as being a part of complete sys^–tern if it meets all of the following conditions.

(a) it is, of a kind solely or principally used in an automatic data processing system.

(b)it’ is connectable to the central processing through directly or through one or more

(c) it is able to accept of deliver data in form(codes or signals) which can be Used by the system.

Note 5 (C) Separately presented units of an automatic data processing machine are to be classified in heading 84.71.

Note 5 (D) Printers, Keyboards,^–X-Y co-ordinate input devices, and disk storage units which satisfy the conditions of paragraphs (13) (b) and (B) (c) above, are in all cases to be^–classified as units 0 1 heading_. 84.71.

Note 5 (E) Machines performing a *specific function other than data processing. and incorporating’ working in conjunction with .an automatic data processing machine arc to be classified. in the headings appropriate to there spectate functions or, failing that, in residual headings…

8. The applicant further submitted that the “Espressif ESP32-C3-.1)evKitM-1₇N4X Development Board (Microcontroller Development Board)”, in the form it is imported, is for general-purpose use and can be programmed for various applications by installing the software. This development board is not a finished consumer product, but a programmable development hoard intended for integration into systems or for software and educational use. The Board base material is known as a Printed Circuit Board on which. the Integrated • Circuits and• other electronic active/passive elements are fixed. The subject goods act as the brain of the machines; where it is fixed because it contains a Central Processing Unit, Memory, etc. The Board integrates complete wi_Tfi and I3luctooth low energy, functions. The subject goods do not contain any housing or input or output devices. The goods have multiple applications in the various Industries. it is not a specific part of any machine or specific type of machine. It has to be programmed with the application Software before using it for any specific purpose, or with a particular type of machine in a particular industry, or for general educational/domestic use. The software programming .for a specific purpose is a post-import activity. But as per the classification rules of import, the goods have to be classified in the form it is imported.

Thus, in this case, the subject goods, viz. “Espressif ESP32-C3-DevKitNI-1 N4X Development Board (Microcontroller Development Board)” is a digital data processing machine without housing or without any input/output devices. It is -capable of fulfilling ‘the following functions-laid down in Note 5(A) (a) of Chapter 84, such as:

(i) Storing the processing program or programs and at least the data immediately necessary for the execution of the program;

(ii) Being freely programmed in accordance with the requirement of the user;

(iii) Performing arithmetical computations specified by the user;

(iv) Executing, without human intervention, a processing program which requires them to modify their execution, by logical decision during the processing run.

Further, the subject goods do not satisfy the functions laid down in Note 5(E) of Chapter It is not a machine performing a specific function. Therefore, in view of the aforesaid facts and clarification, the subject goods are specifically covered under the heading 8471 -• Automatic data processing machines and units thereof. The specific heading prevails over the general heading. The subject goods are not covered under 847130, 84714 484749 & 847150 because it does not contain housing, any input or output devices. The most appropriate heading is 84719000.

9. Furthermore, the Specific Heading will prevail over the General Heading:

(i) it is a trite law that whenever there is a specific entry, the same would prevail over a general entry. The said general principle is statutorily incorporated in the General Rules of Interpretation, in particular, under Rule 3(a) of the General Rules of Interpretation, which reads as under:

“Rule 3. When by application of Rule 2(b) or for any other reason, goods arc, prima facie, classifiable under two or more headings, .classification shall be effected as follows:

(a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods or to part only of the items in a set put up for retail sale, those headings are to be regarded as equally specific in relation to those goods, even if one of them gives a more complete or precise description of the goods….”

(ii) The applicant submitted that when construing a general and a specific statute pertaining to the same topic, it is necessary to consider the statutes as consistent with one another and such statutes, therefore, should be harmonised, if possible, with the objective of giving effect to a consistent legislative policy. On the other hand, where a general statute and a specific statute relating to the same subject-matter cannot be reconciled, the special or specific statute ordinarily will control.

(iii) in this context, it may also be useful to refer to the f011owing judgment, wherein the above maxim/principle has been applied by the Courts in India while dealing with fiscal statutes:

M/s. Moore° (India) Ltd. v. Collector of Customs, 1994 Supp (3) SCC 562 — 1994 (74) 5 (S.C.) = 1994 taxmann.com 265 (S.C.) :

“4. The specific heading of classification has to be preferred over general heading. The clause contemplates goods which may be satisfying more than one description. Or it may be satisfying specific and general description. In either situation the classification which is the most specific has to be preferred over the one which is not specific or is general in nature. In other words, between the two competing entries the one most nearer to the description should be ‘preferred. Where the class of goods manufactured by an assessee falls say in more than one heading one of which may be specific, other more specific, third most specific and fourth general, the rule requires the authorities to classify the goods in the heading which satisfies most specific description….”

(iv) Further, submitted that, in this case, the CTIT 8471 is a specific entry insofar as ii covers “Data Processing Machine”, in view of the above-settled rule that a specific entry would prevail over a general entry. Therefore, the impugned goods-are correctly covered under CTI 84719000.

10. The applicant submitted that, as per the explanatory notes of CITH 8542,the headings exclude “Mountings one or more discrete coinponents on a support formed, for example, by a printed Circuit” Further, in the subject goods, the active and passive elements are fixed on a printed circuit board. Therefore, the subject goods arc excluded from CTII 8542, and it is correctly covered under CM-8471.

11. The applicant stated that, the subject goods cannot be classified as part Of any machine because, in the forth it is imported cannot be used as assemblies in the heading appropriate to the machine or appliance. Further, the subject goods do not satisfy the ^–functions laid down in Note 5(E) of Chapter 84. It is not a machine performing a specific function but a freely programmable board/machine, After clearance of the goods for home consumption, it is a post-import activity to program the development board with the application Software before using it for. any specific purpose,^– or with a particular type of machine in a particular industry, or for general education/domestic use. Therefore, the form that the subject goods will be imported will be only a data processing machine without any housing or any input/output devices. it is considered a freely programmable, entry-level development board featuring the ESP32-C3 chip with integrated Wi-Fi and Bluetooth LE, offering accessible GPIOs for IOT projects, making it.. ideal for hobbyists and professionals to build connected devices easily.

12. On behalf of the applicant, they submitted that, the classification has to be seen at the time of import by the importer and not the use to which it will be^. put by the buyers of goods from thc applicant. The extract of the case law supporting our contention is reproduced below:

Hemant Subhas ‘Take V/s. Union of India 2024(389)E.L.T.161 (BOM)

Provisional release of goods – Ethyl Alcohol Absolute – Classification dispute By virtue gills purity of 99.9N and markings, identified as meant _.for use solely as Laboratory Chemicals ­Admittedly, Petitioner-importer was regular importer of Ethyl Alcohol Absolute for last many years and classification under Heading 98.02 of Customs Tariff was accepted by Revenue ­Ethyl Alcohol Absolute was in bottles of 500 ml. and conformed to marking requirements as per Chapter 98 of Customs 7’arif f Act, 1975 – Classification had to be seen at time of import by importer and not use to which it was put by buyers of goods from Petitioner – Chapter 98 ibid. did not imposed such obligation on importer – Revenue was not justified in refusing to release Ethyl Alcohol Absolute provisionally = Therefore, importer would be entitled for provisional release of Ethyl Alcohol Absolute on execution of bond by importer to secure differential duty and consequential amount, if any – Section 1 10-.4. of Customs Act, 1962 – Tariff Headings 22.07 and 98.02 of First Schedule to Customs Tariff Act, 1975. fares 27; 28 and 297

The applicant also submitted that, from the aforesaid grounds/clarifications, it is evident that, the impugned goods arc properly arid correctly covered under_. Customs Tariff ‘leading 8471 and Customs Tariff Item 84719000 of the Customs Tariff Act, 1975, as_. per Note 3(a) of the General Interpretative Rules (GIR) of the classification of the goods.

13.1 The imported second goods “SOC Product —Espressif ESP32-C3-WROOM-02- N4 Module” are properly and correctly covered under CTI 84733010. The application of “SOC Product —Espressif ESP32-C3-WROOM-02-N4 Module” for ready reference is reproduced below:

The Espressif ESP32-C3-WROOM-02-N4 is a compact IoT module featuring the ESP32-C3 System-on-Chip (SoC), providing integrated Wi-Fi (802.11 b/g/n) and Bluetooth 5 (LE), built around a low-power RISC-V core with up to 4MIB Flash memory and a PCB antenna, ideal^– for cost-effective smart devices needing wireless connectivity and security features like secure boot and flash encryption, as detailed on Espressif s product pages and developer resources. The Espressif ESP32-C3-WROOM-02-N4 is built around an ESP32- C3 microcontroller System on a Chip (SoC), making it a powerful, integrated solution for IoT with a RISC-V core, Wi-Fi, Bluetooth, and peripherals, not just a simple microprocessor but a Cull microcontroller SoC.

Key Components & Features:

• Core: A 32-bit RISC-V single-core processor, running up to 160 MHz
• Connectivity: Integrated 2.4GHz Wi-Fi (802.11 b/g/n) and Bluetooth 5 LE (Low Energy ).
• Memory: Includes 41\413 external SPI Flash (the ‘N4’ in the name), 400K13 SRAM, and 384K13 ROM on the chip.
• Peripherals: Rich set of GPIOs, ADC, CART, SPI, 12C, PWM, and a USB Serial/JTAG controller for programming/debugging.
• Module Design: Comes as a compact module with an integrated PCB antenna for easy integrati6n into devices.

13.2 Photo of “SOC Product —Espressif ESP32-C3-WROOM-02-N4 Module” found on the Website is as below:

13.3 The extract of the CHI 8473 for case pf reference is reproduced below:

13.4 The applicant further submitted that, “SOC Product – Espressif ESP32-C3-WROOM-02-N4 Module” is a part of “Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board)”. The “SOC Product – Espressif ESP32-C3-WROOM-02-N4 Module” contains a microprocessor – a 32-bit RISC-V single-core processor. It is solely and principally used with a data processing machine covered under CTH 8471. The “Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board)” is a data processing machine, and it is specifically covered under Heading 8471 – Automatic data processing machines and units thereof. The parts and accessories suitable for use solely or principally with machines of headings 8470 to 8472 are covered under Heading 8473. Therefore, the “SOC Product – Espressif ESP32-C3-WROOM-02-N4 Module”, being a microprocessor and a part of the data processing machine, is correctly, properly, and specifically covered under CTH 84733010.

13.5 The Specific Heading will prevail over the General Heading:

(i) It is a trite law that whenever there is a specific entry, the same would prevail over a general entry. The said general principle is statutorily incorporated in the General Rules of Interpretation, in particular, under Rule 3(a) of the General Rules of Interpretation, which reads as under:

“Rule 3. When by application of Rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows:

(a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods or to part only of the items in a set put up for retail sale, those headings are to be regarded as equally specific in relation to those goods, even if one of them gives a more complete or precise description of the goods….”

(ii) Applicant submitted that, in this case, the CTH 84733010 is a specific entry insofar as it covers “Microprocessor”. In view of the above-settled rule that a specific entry would prevail over a general entry, therefore, the impugned goods are correctly covered under CTH 84733010.

From the aforesaid grounds/clarifications, it is evident that, the impugned goods are properly and correctly covered under Customs Tariff Heading 8473 and Customs Tariff Item 8473301.0 of the Customs Tariff Act, 1975, as per Note 3(a) of the General Interpretative .Rules (GIR) of the classification of the goods

14. The applicant has submitted the additional submissions vide letters dated 06.03.2026 and 07.03.2026 stated that:

14.1 What arc the primary and secondary functions of “Epressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board)” and the “SOC Product -Espressif ESP32-C3- \VROOM-02- 4 Module”:

(a) The manufacturer supplier M/s. Espressif China has submitted a Technical Clarification /Literature for the Exported Product “ESP32-C3-DcvkitM-1-N4X & Part of this product ESP32-C3-MIN1-1-N4X.” The supplier Espressif Systems designs and manufactures high-performance microprocessor systems engineered for reliability, scalability, and efficient integration across embedded and industrial applications.

In the technical literature, the supplier has stated that, the primary function of the ESP32 is to process and manage data within embedded systems. The CPU/microprocessor in all ESP32 modules is the primary function and operates independently, performing data processing. control, and peripheral management without requiring any wireless hardware support. Wi-Fi and Bluetooth are secondary functions, and can be enabled or disabled via software depending on application requirements.

Key Points:

• Primary Function: CPU/microprocessor handles all data processing and control independently; without relying on Wi-Fi, Bluetooth, or other hardware modules.
• Secondary Functions: ‘Wireless connectivity (Wi-Fi/Bluetooth) is available in some series but is optional and can be disabled via software for secure, low-power, or wired-only applications.
• Flexibility: System designers can choose modules with or without wireless features depending on application needs. •

(b) The applicant has also submitted a separate Technical Clarification/ Literature of Independent & Primary Microcontroller / Microprocessor Functionality. Regarding the products: .

As per the applicant, the CPU/microprocessor in all ESP32 modules is the primary function and operates independently, performing data processing, control, and peripheral management without requiring any wireless hardware support. Wi-Fi and Bluetooth arc secondary functions, available in’ certain series or module variants, and can be enabled, disabled, or omitted entirely depending on application requirements.

From the technical clarifications/literatures, submitted by the manufacturer supplier and the applicant, it is evident that the primary function of “Espressif ESP32-C3-DevKitM- – 4X Development Board (Microcontroller Development Board)” and the “SOC Product – Espressif ESP32-C3″-WROOM-02-N4 Module” is to process and manage data within embedded systems and control independently, without relying on NATI-Fi, Bluetooth, or other hardware modules and the Wi-Fi and Bluetooth are second certain series or module variants, and can be enabled, disabled, or omitted entirely depending on application requirements.

14.2 The “Espressif ESP32-C3₇.1)evKitM-1₇N4X Development . Board (Microcontroller Development Board)” is more appropriately covered under the. HS Code ..84719000,..and the “SOC Product – Espressif ESP32-C3-WROOM-02-N4 Module” is more appropriately covered under the HS Code 84733010:

(A) “Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board)” is more appropriately covered under the HS Code 84719000:

I. The application of “Espressif ESP32-C3-DevKitM-1-N4X Development Board”^– is a microcontroller that functions as an automatic data processing machine.

II. Applicant submits that the “Espressif ESP32-C3-DevkitM-1-N4X Development Board (Microcontroller Development Board)”, in the form it is imported, is for general-purpose use and can be programmed for various applications by installing the software. This development board is not a finished consumer product, but a programable development board intended for integration into systems or for software and educational use. The Board base material is known as a Printed Circuit Board on which the Integrated Circuits and other electronic active/passive elements are fixed. The subject goods act as the brain of the machines, where it is fixed because it contains a Central Processing Unit, Memory, etc. The board integrates Wi-Fi and Bluetooth Low Energy (BLE) functionality”. The subject goods do not contain any housing or input or output devices. The goods have multiple applications in the various Industries. It is not a specific part of any machine or a specific type of machine. It has to be programmed with the application Software before using it for any specific. purpose, or with a particular type of machine in a particular industry, or for general educational/domestic use. The software programming for a specific purpose is a post-import activity. But as per the classification rules of import, the goods have to be classified in the forth it is imported.

III. Thus, in this case, the subject goods, viz. “Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontr011er Development Board)” is a digital data processing machine without housing or without any input/output devices. It is capable of fulfilling the following functions laid down in Note 5 (A) (a) of Chapter 84.

Therefore, in view of the aforesaid facts and clarifications; the subject goods are specifically*covered under the heading 8471 – Automatic data processing machines and units thereof. The specific heading prevails over the general heading. The subject goods are not covered-under 847130, 847141, 847149, & 847150 because it does not contain housing, any input or output devices. The most appropriate heading is 84719000.

IV. Further, from the aforesaid grounds/clarifications, it is evident that, the impugned goods are properly and correctly covered under Customs Tariff Heading 8471 and Customs Tariff Item 84719000 of the Customs Tariff Act, 1975, as per Note 3(a) of the General Interpretative Rules (GIR) of the classification of the goods.

(B) “SOC Product-Espressif ESP32-C3-WROOM-02-N4 more appropriately covered under the HS Code 84733010:

(I) Applicant submitted that, “SOC Product -Espressif ESP32-C3-WROOM-02- N4 Module” is a part of “Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board)”. The “SOC Product -Espressif ESP32-C3-WROOM-02-N4 Module” contains a microprocessor – A 32-bit RISC-V single-core processor. It is solely and principally used with a data processing machine covered under CTII 8471. The “Espressif ESP32-C3-DevKitM-1-N4X Development Board .(Microcontroller Development Board)” is a data processing machine, and it is specifically covered under the heading 8471 -Automatic data processing machines and units thereof. The parts and accessories suitable for use solely or principally with machines of heading 8470 to 8472 arc covered under heading 8473. Therefore, the “SOC Product – Espressif ESP32-C3-WROOM-02-N4 Module”, being a microprocessor and a part of the data processing machine, is correctly, properly, and specifically covered under 84733010.

(ii) Applicant submitted that, from the aforesaid grounds/clarifications, it is evident that, the impugned goods are properly and correctly covered under Customs Tariff Heading 8473 and Customs Tariff Item 8473.3010 of the Customs Tariff Act, 1975, as per Note 3(a) of the General Interpretative Rules (GIR) of the classification of the goods.

15. Port of Import and reply from jurisdictional Commissionerate.

The applicant in their CAAR-1 indicated that they intend to import the subject goods from the jurisdiction of Office of the Commissioner. of Customs, Air Cargo Complex, Mumbai and Nhava Sheva-V, JNCH, Uran. In terms of Provisions of the Section 28-1(1) of the Customs Act. 1962_. read with the Sub-regulation No. (7) of the Regulation No. 8 of the Customs Authority for Advance Rulings Regulations, 2021, the application was forwarded to the office of the Commissioner a_:Customs, Air Cargo Complex, Mumbai on. and Nhava Sheva-V, INCH, Uran on 09.01:2026 as indicated by the applicant at Sr. No. 13 of their CAAR-1 Forms calling upon them to furnish -the relevant records with comments, if any, in_: respect of the said application. Further reminders Were also sent to ACC, Mumbai on 27.01.2026 and 13.02.2026 and Nhava Sheva-V, JNCH, Uran on 27.01.2026, 16.02.2026 and 12.03.2026 to the concerned jurisdictional commiserates.

The Air Cargo Complex, Mumbai Customs Commissionerate vide its letter No. CUS/APR/MISC/907/2026-Gr.5 dated 18.02.2026 submitted-the comments / opinion ‘on the applicant’s application sought under Advance Ruling as under:

(i) ESP32-C3-D.evKitiVI-17N4X Development. Board under CTI-I 8471: As per Chapter Note 5(A) to Chapter 84, an automatic data processing machine must be capable of general-purpose data processing. The subject goods appear to function as embedded programmable controllers intended for incorporation into other equipment and perform specific control communication tasks. They do not appear to operate as standalone computers and lack essential characteristics of ADP :machines such as independent user interface, storage media and general computing environment. Further, Chapter Note 5(E) excludes machines performing specific functions even if incorporating a processing unit. Hence, classification as ADP machine or unit thereof’ under heading 8471 appears .not appropriate.

(ii) ESP32-C3 WROOM-02-N4_: Module under 8473: The essential character of the goods is derived from the semiconductor microcontroller/SoC mounted on PCB with supporting components. The development board Merely facilitates interfacing and testing and does not alter the fundamental character of the electronic module. The goods therefore appear to- be Programmable electronic modules based on semiconductor devices used for control and communication functions in other equipment. Such goods merit consideration under Chapter 85 (CTFI 8542) (electronic integrated circuits/modules) rather than Chapter 84.

In view of above, though the application is admissible under Section 28F of the Customs Act, 1962. However, based on functional characteristics” and technical composition, the classification claimed ‘under heading 8471/8473 requires reconsideration…The goods appear more appropriately classifiable as semiconductor electronic modules under Chapter 85 (CTII 8542)

16. Details of Personal Hearing:

Shri Lawrence Stanley Tauro, Advocate and Atul M. Dumbre, appeared for Personal Hearing in this matter on 25.02.2026. They reiterated the contention filed with the application that the subject goods are (a) ESP32–C3 Espressif a Development Board (Microcontroller Development Board) and (b) SOC^– (system on chip) product being unit of ADP machines and merit classification under CTH 8471 and 8473 more particularly under. CTI 84719000 .and 84733010 respectively. That the unit ESP32-C3 Espressif is not. a finished consumer. Product but a programmable development board intended for integration into system or software and function like ADP machine. That it contains processing unit, data acquisition, control and data transmission, whereas the other product SOC comprises processing core integrated with Wi-Fi, Bluetooth and flash memory capability.

16.2 Nobody appeared for Personal Hearing from the Department side.

16.3. The applicant, in their additional submissions vide letter dated 25.04.2026 supinated that –

• The Espressif l’,SP32-C3-DevKitM-1-N4 is a general-purpose, entry-level development board designed for prototyping and evaluating the ESP32-C3 series of microcontrollers, rather than being a specific, proprietary component for dedicated telecommunication infrastructure. It is widely used in applications such as the Internet of Things (IoT), smart home devices; consumer electronics; and industrial automation.
• Core Component: It features the ESP32-C3-MINI-1 module, which is based on the ESP32-C3 single-core RISC-V microcontroller Wireless Functionality: It supports Wi-Fi and Bluetooth Low Energy. Purpose: It is meant for developers to “flash” their own firmware and build connected devices, featuring 4 MB of external SPI flash for user applications.
• Interface: It provides a USB-to-UART bridge, a micro-[TSB port, .for power/programming, and breaks out GPIO pins for interfacing with sensors and other peripheral devices.

While it handles wireless communication, it is designed for general application development, not specialized, restricted telecommunication network equipment.

c) The subject goods are typically not classified under HS Code 8517 because it is a development tool meant for evaluation and prototyping rather than a finished consumer communication device.

(d) In customs and trade classification, HS Heading 8517 generally covers finished products for the transmission or reception of voice, images, or other data, such as smartphones, routers, or IP phones. The ESP32-C3-DevKitM-1 is instead categorized as a microcontroller-based evaluation board.

c) Note 4 to Section XVI (Chapters 84-85) of the Harmonized System (HS) defines the classification of functional units. It states that when a machine (or combination of machines) consists of separate components intended to contribute together to a clearly defined function. the whole falls to be classified in the heading appropriate to that function. The IspressifISP32-C3-DevKitM-1-N4x is not a network interface card (NIC) because it is a microcontroller development board.

Key Reasons for Exclusion from 8517:

(i) Primary Function: Heading 8517 focuses on “Apparatus for the transmission or reception of voice, images or other data.” While the ESP32-C3 has Wi-Fi and Bluetooth capabilities, the. Devkit is designed as a development platform for software engineers to write code and test hardware peripherals, not as a standalone communication apparatus.

(ii) Physical Form: The board is an “entry-level development board” with broken-out I/O pins for easy interfacing with jumper wires or breadboards. It lacks the housing, user interface, or specific telephony/network termination circuitry characteristic of 8517 steins like I P Phones.

(iii) Moreover, because the Development Boards’ only function is data processing, It falls outside the scope of Note 5(E) to Chapter 84 and is classifiable under heading 8471, IITSUS. See Note 5(E), Ch. 84. We also find that the wireless functionality of this kit does not influence its classification because it doesn’t change the underlying function of the goods.

Further, the applicant relied on two US rulings:

(a) US Ruling No. HQH07,0862 dated 01.09.2009- Tariff Classification of Atmel starter kits, evaluation kits and expansion kits.

We find that the Raven. kit is a functional unit, describe din Note 4 to Section XVI, because the components, of the kit all work together to program the chips on the boards. See supra Note 4, Sec. XVI. We also find that the kit is classifiable as a unit of an ADP system because it meets the requirements of Note 5(C) to Chapter 84. Moreover, ‘because its only function is data processing, it falls outside the scope of Note .5(E) to Chapter 84 and is classifiable under heading 8471. HTSUS:. See Note 5(E), Ch. 84. We also find that the wireless fictionality of this kit doe; not influence its classification because it does not change the’ underlying function of the good.

The subject development board’s key function. is to process and manage data Withing embedded system, In view of the Section Note 3 to Section XVI and US ruling, the goods; ate Under CTI 847330.

(b) Ruling No. NY N292764 dated 09.01.2918- The, tariff ‘classification of an Exaptation Board FNAD Singapore. The merchandise under Consideration is referred to :as ‘an Evaluation Board, PN AD-FMCDAQ2-EBZ. This printed circuit board assembly (PCBA) contains processors, digital to analog converters, analog to digital converters, field programmable gate-arrays (FPGA), and input/output connectors In use, the subject Evaluation Board is described as a design tool distinct end uses and is identified first as an “evaluation board” and secondly as a “data acquisition and signal synthesis module”.

When functioning as an Evaluation Board, the PCBA is connected to an Automatic Data Processing (ADP) machine and various integrated circuits (IC) are tested to assess the performance capabilities of the circuit while providing the user with data to determine how the will work within a certain product. When the Evaluation its host ADP Machine,. it. receives its power from the ADP machine. Furthermore, in this scenario the program required to analyze the IC is running on the ADP machine as well. The instant Evaluation Board is akin to the previously ruled upon PCBAs in HQ ‘.11^.0’19395, where both connect directly to “an ADP Machine and each are used for the, purpose of data collection and analysis of ICs.

When functioning as a data acquisition board, the PCBA is connected W the user’s carrier board which’ allows them. to view wideband radio frequency (RF) data that is stored in the FPGA and played back for testing and development purposes. We would note that when used as a RF data acquisition board, it is not connected to an_. ADP machine and, is in standalone configuration. While in standalone mode, power is received from a wall outlet and user interface is achieved by connecting the separate carrier board to ‘a mouse, keyboard, and display unit.

Classification under the Harmonized Tariff Schedule of the United States. (HTSUS), is made in accordance with the^. General Rules^–of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule arid any relative Section or ‘Chapter Notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs may then be applied in their appropriate order.

Note 3 to Section XVI states that machines designed for the purpose of performing two or ‘more complementary or alternative functions are to be. Classified as if consisting only of that component which. performs the principal. function. As noted above, the subject PCBAs have two key functions. The firs function is to interface with an ADP machine to record the behavior and performance data of ICs for designing various products. This data processing function is described by the heading text of 8473, IITSUS. The second function is to test and record RF carrier, signals and present the Waveform findings on a display device, f4’id as previously mentioned, this is accomplished in a standalone configuration where no ADP machine is used. This function is not specifically described in the Nomenclature and as such, is provided for by^. the heading’ text of 8543, HTSUS.

In your, request you suggest the Evaluation Board is classifiable as. a printed circuit board assembly under 8473.30.1180, HTSUS. For an alternate classification, you suggest the subject PCBA is accurately described as an “other electrical machine and apparatus, having an individual function, but net provided for elsewhere” in 8543.70.9960, HTSUS. As^. the subject PCBA has two distinct functions, it must first be determined if one of those functions is considered the principal function.

Based on the information you have provided as well as its physical description, the way consumers principally use the device, and the manner in which it is marketed, described, and advertised, we find that the essential character of the subject Evaluation Board is accurately described as a printed circuit assembly for the machines of heading 8471, LITSUS. Therefore, we agree with your suggested classification.

The applicable subheading for the Evaluation Board, PN AD-FMCDAQ2-EBZ will be 8473.30.1180, I ITSIJ S, which provides for “Parts and accessories … suitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Printed circuit assemblies.”

16.4 Further, the applicant vide letter dated 19.05.2026 submitted that the subject goods are correctly classifiable under CTH 8542 as per note 3(a) of the General Interpretative Rules (GIR) or 8471 or 8473 of the Customs Tariff Act, 1975.

16.5 Since the Authority for Advance Ruling has undergone a change, a fresh personal hearing was granted on 22.05.2026 in adherence to the principles of natural justice. During the said hearing, the authorised representative revised his earlier stand and requested that the same be duly considered.

16.5.2 Nobody appeared for Personal. Hearing on behalf of the department.

17. Discussion and Findings: –

17.1 I have carefully gone through the application filed by the applicant, the written submissions, additional submissions on 06/07.03.2026, the technical literature and the documents placed on record. I have also considered the arguments advanced during the course of personal hearing held on 25.02.2026. I have further examined the relevant provisions of the Customs Tariff Act, 1975, the General RuleS for Interpretation (GIR), the relevant Section Notes and Chapter Notes, and the IISN Explanatory Notes which provide guidance for classification of goods under the Customs Tariff.

17.2 The issue for determination in the present case relates to the classification of “Espressif ESP32-C3 DevKitM-1-N4X Development Board (Microcontroller Development Board)” and “SOC Product —Espressif ESP32-C3-WROOM-02-N4 Module” proposed to be imported by the applicant.

17.3 At the outset, I find that the issue raised by the applicant squarely falls within the ambit of Section 28H(2)(a) of the Customs Act, 1962, as it relates to the classification of goods under the Customs Tariff Act, 1975.

17.4 The applicant submitted that both. products are microcontroller-based embedded professing systems designed for programmable data processing and control functions. It is submitted that the goods contain CPU, memory, and programmable interfaces, the primary function is data processing and control and Wi-Fi and 13luetooth features are secondary,. optional, and can be. disabled through software. The applicant further contends that the^– goods function as automatic data processing systems, in embedded environments, it is not finished consumer products and classification must be based on condition at import.

Accordingly, the applicant has proposed classification under CTI I 8471 or 8473 or 8542 and the . applicant has relied upon – the judgment of M/s. Morocco (India) Ltd. V. Collector of Customs and Hemant Subhas ‘Pekoe V. Union of India to contend that classification should be based on primary function.

17.5 Classification of goods under the Customs Tariff Act. is governed by the-General Rules for Interpretation (GIR). Rule 1 and Rule 3 of the GIR provides that classification shall’ be determined according to the terms of the headings and any relevant Section or Chapter Notes. Only when classification, cannot be -determined under Rule 1 do the subsequent rules become applicable.

‘Therefore, in the present case, it becomes necessary to examine the scope and coverage of Chapter 84 and Chapter 85, along with the relevant HSN Explanatory Notes.

18.The -applicant stated that “Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board)”, in the form it. is imputed, -is for general-purpose Use and can be-programmed for various applications by installing the software. This development board is not a finished consumer product, but a programmable development board intended for integration into systems or for software and educational use. The Board base material is known as a Printed Circuit Board on which the integrated Circuits and active/passive elements arc fixed. The subject goods act as the brain of the machines, where it is fixed because it contains a Central Processing Unit, Memory, etc The board integrates and Bluetooth Low Energy (13LE) functionality” The subject goods do not contain any housing or input or output devices. The goods have multiple applications in -the various Industries. It is not a specific part of any machine or .a specific type of machine. It has to be programmed with the application Software before using it fin any specific purpose, or with a particular type of machine in a particular industry, or for general educational/domestic use. The software programming for a specific purpose is a post-import activity. The subject goods is a digital data processing machine without housing or without any input/output devices. Thus. the subject goods are specifically covered under the heading 8471 – Automatic data processing machines and units thereof. The most appropriate heading is 84719000. Relevant heading 8471 as under

48471	AUTOMATIC DATA PROCESSING MACHINES AND UNITS THEREOF; MAGNETIC OR OPTICAL READERS, MACHINES FOR TRANSCRIBING DATA ON TO DATA MEDIA IN CODED FORM AND MACHINES FOR PROCESSING SUCH DATA, NOT ELSEWHERE SPECIFIED OR INCLUDED
8471 30	Portable automatic data processing machines, weighing not more than 10 kg, consisting of at least a central processing unit, a keyboard and a display
8471 30 10	Personal computer	u	Free
8471 30 90	Other	u	Free
	Other automatic data processing machines:
8471 41	Comprising in the same housing at least a central processing unit and an input and output unit, whether or not combined
8471 41 10	Micro computer	u	Free
8471 41 20	Large or main frame computer	u	Free
8471 41 90	Other	u	Free
8471 49 00	Presented in the form of systems	u	Free
8471 50 00	Processing units other than those of sub-headings 8471 41 or 8471 49, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units	u	Free
	Input or output units, whether or not containing storage units in the same housing:
8471 60 10	Combined input or output units	u	Free
(1)	(2)	(3)	(4)	(5)
8471 60 24	Graphic printer	u	Free	–
8471 60 25	Plotter	u	Free	–
8471 60 29	Other	u	Free	–
8471 60 40	Keyboard	u	Free	–
8471 60 50	Scanners	u	Free
8471 60 60	Mouse	u	Free	–
8471 60 90	Other	u	Free	–
	Storage units:
8471 70 10	Floppy disc drives	u	Free	–
8471 70 20	Hard disc drives	u	Free	–
8471 70 30	Removable or exchangeable disc drives	u	Free	–
8471 70 40	Magnetic tape drives	u	Free	–
8171 70 50	Cartridge tape drive	u	Free	–
84 71 7060	CD-RON4 drive	u	Free	–
8471 7070	Digital video disc drive	u	Free	–
8471 70 90	Other	u	Free
8171 80 00	Other units of automatic data processing machines	u	Free	–
8171 9000	Other	u	Free	–

Chapter Notes to Chapter 84 are as under :

5 For the purposes of heading 84.62, a “slitting line” for flat products is a processing line composed of an uncoiled, a coil flattener, a slitter and a reboiler. A “cut-to-length line” for flat products is a processing line composed of an uncoiler, a coil flattener and a shear.

6. (A) For the purposes of heading 84.71, the expression “automatic data processing machines” means machines capable of:

(i) Storing the processing program or programs and at least the data immediately necessary for the execution of the program;

(ii) Being freely programmed in accordance with the requirements of the user;

(iii) Performing arithmetical computations specified by the user; and

(iv) Executing, without human intervention, a processing program which requires them to modify their execution, by logical decision during the processing run.

(B) Automatic data processing machines may be in the form of systems consisting of a variable number of separate units.

(C) Subject to paragraphs (D) and (E) below, a unit is to be regarded as being part of an automatic data processing system if it meets all of the following conditions:

(i) It is of a kind solely or principally used in an automatic data processing system;

(ii) It is connectable to the central processing unit either directly or through one or more other units; and

(iii) It is able to accept or deliver data in a form (codes or signals) which can be used by the system.

Separately presented units of an automatic data processing machine are to be classified in heading 84.71.

However, keyboards, X-Y coordinate input devices and disk storage units which satisfy the conditions of paragraphs (C)(ii) and (C)(iii) above, are in all cases to be classified as units of heading 84.71.

(D) Heading 84.71 does not cover the following when presented separately, even if they meet all of the conditions set forth in Note 6(C) above:

(i) Printers, copying machines, facsimile machines, whether or not combined;

(ii) Apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network);

(iii) Loudspeakers and microphones;

(iv) Television cameras, digital cameras and video camera recorders;

(v) monitors and projectors, not incorporating television reception apparatus.

(E) Machines incorporating or working in conjunction with an automatic data processing machine and performing a specific function other than data processing are to be classified in the headings appropriate to their respective functions or, failing that, in residual headings.

I find that the ESP32-C3-DevKitM- I -N4X is a development board, consisting’ of a microcontroller (CPU and memory), printed Circuit Board with mounted components and interfaces and communication capability. As per Chapter Note 6 (A) to Chapter 84, an ADP machine must Store processing programs, be freely programmable, perform arithmetic computations and execute processing logic. automatically. The applicant contends that the development board contains CPU. memory. processes data from sensors and executes instructions. Therefore, qualifies as an ADP system/unit. The ESP32-C3-DevKitM-l-N4X is a standalone embedded system, not a peripheral unit, does not function as part of a conventional ADP system and does not require Monitor, Keyboard, storage system and operates as a controller, not as a computing system. It is designed to control machines, interface with sensors and execute ’embedded logic.

The subject goods appear to function as embedded programmable controllers intended for incorporation into other equipment and perform specific control/communication tasks. They do not appear to operate as standalone and lack the essential characteristics .of ADP: -machines. such as independent user interface, storage media and general-purpose data processing rather they run. on a fixed program to perform a specific task. It is designed for embedded renunciation applications; not a general-purpose computing machine. Therefore, it can be deduced that the subject goods do not fall under the category of ADPM and the concerned Jurisdictional Commissionerate is also of the same opinion.

Further, it can be used with the devices Other than ADPM like smart locks, wearables, industrial controllers and sensors-etc through wi-f, Bluetooth and ports. Therefore,- it can be concluded that the subject goods are not solely and principally be used with ADPM whereas as per Chapter Note 6(C), a unit is to be regarded as parts of ADPM only if it is of a kind solely or principally used in an ADP system, it is connectable to the central processing unit and it is able to accept or deliver data in a usable form. Since, the goods can be connected to other devices, therefore, the same cannot be termed as parts in terms of Chapter Note 6©.

Further, in the case of Commissioner v. Insulation Electrical Private Limited [2008 (224) E.L.T. 512 (S.C.)], the lion!bk Supreme Court held that a ‘part’ is an essential component of the whole without which the whole cannot function. This position has been consistently followed and reiterated in a catena of decisions including the decision of the Hon’ble Supreme Court in the ‘case of CTO, Anti Evasion, Circle III, Jaipur v. Prasoon Enterprises [2019 (23) G.S.T.L. 441 (S.C.)] wherein it was held that the test for a product to be a part of the other is to see if the other is incomplete without the product or if the other cannot function without it. The complexity or lack of complexity will not be a detriment to the question of identifiable nature of the part.

Applying the above judgments in the instant case, it can be deduced that ESP32-C3-DevKitM-1-N4X is not solely and principally to be used with ADPM and also, not an essential component of ADPM without which ADPM will. not be functional, hence, cannot be classified under CTH 8473 as a part.

Therefore, as per Note 6 (D), Heading 84.71 does not cover the Apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network); when presented separately, even if they meet all of the conditions set forth in Note 6 (C) above: and according to Note 6(E) to chapter 84, machines incorporating or working in conjunction with an automatic data processing machine and performing a specific function other than data processing arc to be classified in the headings appropriate to their respective functions or, failing that, in residual headings. Since, the product is not an ADP machine nor a unit of ADP system and it performs embedded control functions. Therefore, CTH 8471/8473 are NOT applicable.

19. Further, the applicant stated about second item that the “SOC Product -Espressif ESP32-C3- WROOM-02-N4 Module” contains a microprocessor – A 32-bit RISC-V single-core processor. It is solely and principally used with a data processing machine. The parts and accessories suitable for use solely or principally with machines of heading 8470 to 8472 are covered under heading 8473. Therefore, the “SOC Product – Espressif ESP32-C3-WROOM-02-N4 Module”, being a microprocessor and a part of the data processing machine, is correctly, properly, and specifically covered under 84733010. Relevant heading 8473 as under:

I find that heading 8473 covers “Parts and accessories suitable for use solely or principally with machines of heading 8471”. Essential Conditions for “Parts” Classification to quality as “parts” must be identifiable as part of a machine, solely or principally used with that machine and not have independent function. As per Chapter Note 6(E) to Chapter 84 is under:

(F.) Machine.; incorporating or working in conjunction ,with an automatic dat..-3 processing machine and performing a specific function other than data processing are to be classified in the headings , appropriate to their respective functions or, fading that, in residual headings.

The subject ESP32-C3-WROOM-02-N4 module does not satisfy these conditions as it is an independent embedded ‘module .capable of processing and transmitting data. Further, Chapter Note 6(E) provides that machines performing a specific function other than data processing are to be classified according to their respective function, even if they incorporate an ADP machine. The subject module performs wireless communication functions (Wi-Fi/Bluetooth) and therefore stands excluded from lIeading 8473.

20. Before deciding the classification of the subject goods i. e. ESP32-C3-DevKi1M- 1 -N4X , it is necessary to understand about ESP32. The Arduino boards are used as development board, built around Basie microcontrollers intended for control-oriented applications, involving input/output interfacing with sensors and actuators; without any inherent capability for wireless communication: such connectivity, if required, is achieved only through external modules. In contrast, ESP32 boards, developed by Espressif Systems, integrate Wi-Fi and Bluetooth functionalities within the same SoC enabling independent data transmission and reception over wireless networks.

From the submissions made by the applicant, I observed that ESP32 module is widely used for developing and manufacturing IoT products that require Wi-Fi or Bluetooth Connectivity. The ESP32-C3-DevKitM-1-N4X is a development board comprising, a microcontroller (CPU and memory), printed Circuit Board with multiple mounted components, interfaces for programming and control and integrated Wi-Fi and Bluetooth. The ESP32–C3 is a compact module comprising system-on-Chip (SoC), integrated.-RE (Wi-Fi/BLE) and memory and antenna. From -the website of the manufacturer i.e.https://documentation.espressif.com/esp32-c3_datasheet_en.pdfi it is observed from the datasheet that ESP32-C3-DevKitM-1 is an entry-level development board based on ESP32-C3-MINI-1 or ESP32-C3-MINI-1U modules, which are named for their compact .size. This hoard integrates complete Wi-Fi and Bluetooth® Low Energy functions. These modules arc the main component of the development board. ESP32-C3-MINI-1 and ESP32-C3-MINI-111 arc general-purpose Wi-Fi and Bluetooth Low Energy combo modules. ESP32-C3-MINI-1 comes with an on- board PCB antenna, whereas ESP32-C3LMINI-1U comes with an external antenna contours. They both have a flash of 4 MB, integrated inside the chip’s package. Block diagram is also referred as under:

The product under consideration is the ESP32 Devkit, a programmable electronic development board incorporating:

• A microcontroller (dual-core processor)
• Integrated Wi-Fi and Bluetooth transceivers
• GPIO interfaces for external peripherals
• Capability to run user-defined embedded software

Both products arc programmable embedded systems used in IOT, automation, and control applications…

The. Chapter heading 8542 covers electronic integrated circuits as such. The applicant’s products lets arc not bare semiconductor devices but assembled electronic modules/boards with-multiple components. Therefore, classification under heading 8542 is not sustainable. Also, as per the HSN explanatory notes to heading 8542, the heading excludes assembly-formed by (a) Mounting one- or more discrete components on a support formed, for example, by a printed circuit; therefore, the subject goods ESP32-0,-DevKitM-1 -N4X development board; having ESP32 Module, Wi-fi, Bluetooth, Antenna, Oscillator, Voltage regulator, GPIO Pins, Reset and Boot Buttons, -Power LED mounted on Printed Circuit Boards arc excluded from the-scope of heading 8542.

Further, the subject goods are primarily used in IoT (Internet of Things) applications for sensing, processing, and communication. The product contains Wi-Fi and Bluetooth modules i.e. ESP32-C3-MINI-1 or ESP32-C3-MINI-11.1 which is a fully integrated wireless communication module. The module is designed for direct integration into electronic devices without the need for additional RF design or circuitry, and is capable of independently performing processing, transmission, and reception of data over Wi-Fi and Bluetooth networks. These SoCs are deployed precisely for transmitting and receiving data over wireless communication in 10’1 ecosystems which is also confirmed by the applicant. Thus, its primary function is to transmit and receive data wirelessly. the inbuilt and primary feature of wireless communication, enabling connectivity to external networks without the need for additional modules, imparts to the goods the essential character of communication apparatus.

The product under consideration is an ESP32-C3, described as an ultra-low-power, highly integrated System-on-Chip (SoC) incorporating a 32-bit RISC-V microprocessor along with in-built 2.4 GHz Wi-Fi and Bluetooth Low Energy (BLE) transceiver functionality. The ESP32-C3 is a highly integrated System-on-Chip whose principal function is to enable wireless transmission and reception of data (Wi-Fi and Bluetooth), while incorporating a microcontroller for processing. and control, thereby functioning as a communication-centric IOT node. The subject goods are based on the ESP32 SoC of Espressif System which integrates, within a single chip, not only a processing unit (CPU and memory architecture) but also a complete 2.4 GHz wireless communication subsystem comprising Wi-Fi (IEEE 802.11 b/g/n) and Bluetooth (BR/EDR and BLE) with inbuilt RF front-end, baseband processing, MAC layer and protocol stack support. The processing core is thus not an independent ADP unit but is architecturally embedded to control and enable the primary function of wireless data transmission and reception. It can be connected to any wi-fi or can create it’s own network over which transmission of data occurs.

In the said datasheet; it is mentioned that the ESP32-C3 chip series group is a low-power solution that provides 2.4. GHz. Wi Fi. (802.11b/g/n) and Bluetooth, 5.0 connectivity, dedicated to smart home applications. Therefore, in view of the above, it is clear that wireless connectivity is the main function of the said SoC which is derived from the ESP32-C3-MINI-1 module embedded on the board.

This development board has the following features:

4.3.1 Radio

This subsection describes the fundamental radio technology embedded in the chip that _.facilitates wireless communication and data exchange.

• • ESP32-C3 radio consists of the following blocks..
  • 2.4 GHZ: receiver .
  • 2 4GHZ.: transmitter
  • Bias and regulators
  • Balum and transmit-receive switch
  • Clock generator

4.3.1.1 The 2.4 GHz receiver demodulates the 2.4 GHz RI? signal to quadrature baseband signals and Converts them to the digital domain with two high-resolution, high-speed ADCs. 7b adapt to varying signal channel conditions, ESP32-C3 integrates RE filters, Automatic Gain Control (AGO. DC offset cancelation circuits, and baseband filters.

4.3.1.2 The 2.4 GHz transmitter modulates the quadrature baseband signals to the 2.4 GI lz R17 signal, and drives the antenna with a high-powered CMOS power amplifier. The use of digital calibration further improves the linearity of the power amplifier Additional calibrations are integrated to cancel any radio imperfections, such as:

• • Carrier leakage
  • FQ amplitude/phase matching
  • Baseband nonlinearities
  • RE nonlinearities
  • Antenna matching

These built-in calibration routines reduce the cost, time, and specialized equipment required for product testing.

4.3.1.3 Clock Generator The clock generator produces quadrature clock signals of 2.4 GIIz for both the receiver and the transmitter: All components of the clock generator are integrated into the chip, including inductors, varactors, filters, regulators and dividers. The clock generator has built-in calibration and self-test circuits. Quadrature clock phases and phase noise are optimized on chip with patented calibration algorithms which ensure the best performance of the receiver and the transmitter .

4.3.2 Wi-hi This ‘subsection describes the chip’s Wi-Fi capabilities, which facilitate wireleSs communication at a high data rate.

4.3.2„1 Radio and Baseband ESP32-C3 Wi-Fi radio and baseband support the following features: • 802.11b/g/n

• • 802. 11n MCSO-7 that supports 20 MHz and 40 MHz bandwidth
  • 802. 11In MCS32
  • 802. 11 n 0:4 ps guard interval
  • Data rate up to 150 Mbps
  • RX STBC (single spatial stream)
  • Adjustable transmitting power
  • Antenna diversity

ESP32-C3 supports antenna diversity with an external RF switch. This switch is controlled by one or more GPIOs, and used to select the best antenna to minimize the effects of channel imperfections.

4.3.2.2 Wi-Fi MAC ESP32-C3 implements the full 802.11 b/g/n Wi-Fi MAC protocol. It supports the Basic Service^– Set (BSS)^.ST4 and SOAP operations under the Distributed Control Function (DCF). Power management is handled automatically with minimal host interaction to minimize the active duty period.

ESP32-C3 Wi-Fi MAC applies the following low-level protocol functions automatically:

• • 4 x Virtual Wi-Fi interfaces
  • Infrastructure BSS in Station mode, SoftAP mode, Station SoftAP mode, and promiscuous mode
  • RTS protection, CTS. protection, Immediate Block ACK
  • Fragmentation and defragmentation
  • 7X/RX TX/RX A-MSDU
  • “Transmit opportunity (TXOP)
  • Wi-Fi multimedia (WMM)
  • GCMP, COMP, TKIP, WAN WEP, BIP, WPA2-PSK/WPA2-Enterprise, and WPA3-PSKIWPA3-Enterprise
  • Automatic beacon monitoring (hardware TSP)

4.3.2.3 Networking Features

• Espressif provides libraries _.for TCP/IP networking, ESP-WIFI-MESH networking, and other networking protocols over 1.0, 1.1 and 1.2 is also supported.

4.3.3 Bluetooth LE

This subsection describes the chip’s Bluetooth capabilities, which facilitate wireless communication for low power; short-range applications. ESP32-C3 includes a Bluetooth Low Energy subsystem that integrates a hardware link layer controller, an RF/modem block and a feature-rich software protocol stack. It supports the core features of Bluetooth 5 and Bluetooth mesh.

4.3.3.1 Bluetooth LE PHY

Bluetooth LOIN Energy radio and PHY in ESP32-C3 support:

• • 1 Mbps PHY
  • 2 Mbps PHY for higher data rates
  • Coded PHY for longer range (125 Kbps and 500 Kbps) before talk (LBT)_.

4.3.3.2 Bluetooth LE Link Controller Bluetooth Low Energy Link Layer Controller in ESP32-t.C3 supports:

• • LE Advertising EXie781011S, to enhance broadcasting capacity and broadcast more intelligent, data
  • Multiple advertising sets
  • SiMU11011CQUS advertising and scanning
  • Multiple connections in simultaneous central and peripheral roles
  • Adaptive Frequency Hopping (AFH) and channel assessment
  • LE Channel Selection Algorithm #2
  • Connection parameter update
  • high null- Cycle Non-Connectable Advertising
  • LE privacy 1.2
  • LE Data Packet Length Extension
  • Link Layer Extended Scanner Filter policies
  • Low duty cycle directed advertising
  • Link layer encryption
  • LE Ping

From the above, it is clear that transmission and reception of data is riot incidental but a built-in and defining capability of the subject goods. The subject product is specifically designed to transmit and receive data over wireless networks (Wi-Fi/Bluetooth); and to operate as a communication node in IOT ecosystems such as smart devices, sensor hubs, automation systems, etc. flic embedded microcontroller, memory, and peripherals facilitate data processing and interfacing;

however, such friction alities are ancillary and supportive to the core wireless communication capability. Its preprimary use is in IOT systems where it acts as a wireless communication node.

On a detailed examination of the technical literature and functional architecture, it is observed that the subject product, namely ESP32-C3, incorporates an integrated RI’ front-end together with Wi I i and Bluetooth Low Energy bask band and protocol control units. The device comprises 2.4 GIlz .transmitter and receiver, Wi-Fi MAC, and baseband, and Bluetooth LE link controller and baseband, thereby enabling processing of data in accordance with standard wireless communication protocols. The embedded microcontroller and associated memory subsystems facilitate packet formation addressing. error handling, and control of communication processes. Thus, the product is designed to enable transmission and reception of data over wireless networks.

I find that the case laws and US rulings cited by the applicant is not applicable inn this ease as the subject goods are different from the goods mentioned in the. said case laws :and ruling in terms of structure, features, design, manufacturer and components therefore such case laws and ruling issued in another country has no obligation upon this authority.

It is further observed-that, in operation, the product performs both transmission and reception of data, inasmuch as digital data is modulated. into RF signals ‘for _transmission and, conversely, incoming RF signals arc received, demodulated, decoded, and processed into-usable data. These functions -are carried out within the ‘same integrated system, with an internal mechanism’ for coexistence and switching between Wi-Fi and Bluetooth operations. Accordingly, the product answers to the description of “apparatus for the transmission or reception of data” as covered under Heading 85I7. 1=he transceiver functionality is not incidental but constitutes the principal and defining function of the product; whereas the embedded processing and peripheral interfaces are ancillary and supportive thereto. Hence, the subject goods are appropriately aligned with the scope and coverage of 1 leading 8517.

21. Further, I find that -the product ESP32-C3-DevKitM- I-N4X Development Board incorporating. thciESP:32-C3 system-on-chip through -the ESP32-C3-MfNI-1 module; and functions programmable era bedded. platform providing integrated- Wireless communication capabilities, which (2-.4 GHz) Bluetooth Low Energy (BLE),- along with microcontroller based data processing It. facilitates transmission and. reception of data in. IOT. applications,- while also- enabling interfacing with- external peripherals through standard protocols such.. as IC, SPI .and DART via exposed GPIOs: The board further includes ancillary features such as USB-based programming and debugging interface, voltage. regulation and boot/reset circuitry, which collectively support firmware development, testing and prototyping:’

The principal function- of the subject goods-is derived from the integrated ESP32,LC34 MIND-1. module, which incorporates a 2.4 GHz RE transceiver enabling Wi-Fi and Bluetooth Low energy (ISLE.) communication, thereby allowing transmission and reception of data over wireless works. The embedded microcontroller primarily operates to execute communication protocols and manage data exchange, rendering the processing function ‘ancillary to the communication role. The additional features present on the development board; such- as USB interface, power regulation and G PIO exposure, merely .facilitate programming and interfacing during development and do not alter the essential character of the goods i.e. wireless communication. Accordingly, the product is correctly classifiable under CTH I 8517 62 90 on the basis of GRI Rule 3(b). which states that-

Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3 (a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable.

Since, wireless communication is the primary function of the subject goods therefore, merit classification under CTI-I 8517. Relevant Chapter heading 8517 is under:

8517	TELEPHONE SETS, INCLUDING SMARTPHONES AND OTHER TELEPHONES FOR CELLULAR NETWORKS OR FOR OTHER WIRELESS NETWORKS; OTHER APPARATUS FOR THE TRANSMISSION OR RECEPTION OF VOICE, IMAGES OR OTHER DATA, INCLUDING APPARATUS FOR COMMUNICATION IN A WIRED OR WIRELESS NETWORK (SUCH AS A LOCAL OR WIDE AREA NETWORK), OTHER THAN TRANSMISSION OR RECEPTION APPARATUS OF HEADING 8443, 8525, 8527 OR 8528
	Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks:
8517 11	Line telephone sets with cordless handsets:
8517 11 10	Push button type	u	Free
8517 11 90	Other	u	Free
8517 13 00	Smartphones	u	20%
8517 14 00	Other telephones for cellular networks or for other wireless networks	u	20%
8517 18	Other:
8517 18 10	Push button type	u	Free
8517 18 90	Other	u	Free
	Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network):
8517 61 00	Base stations	u	**20%
8517 62	Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus:
8517 62 10	PLCC equipment	u	Free
8517 62 20	Voice frequency telegraphy	u	Free
8517 62 30	Modems (modulators-demodulators) for xDSL based wireline telephony	u	Free
8517 62 50	Digital loop carrier system (DLC)	u	Free
8517 62 60	Synchronous digital hierarchy system (SDH)	u	Free
8517 62 70	Multiplexers, statistical multiplexers for PDH based wireline telephony	u	Free
8517 62 90	Other	u	20%
8517 69	Other:
8517 69 10	ISDN System	u	Free
8517 69 20	ISDN terminal adaptor	u	Free
8517 69 40	X 25 Pads	u	Free
8517 69 60	Set Top Boxes for gaining access to internet for wireline telephony	u	Free
8517 69 70	Attachments for telephones	u	Free
8517 69 90	Other	u	20%
8517 71 00	Parts: Aerials and aerial reflectors of all kinds; parts suitable for use therewith	u	20%
8517 79	Other:
8517 79 10	Populated, loaded or stuffed printed circuit boards	u	20%
8517 79 90	Other	u	15%

In terms of Section Note 3 to Section XVI, composite machines arc to be classified recording to their principal function. The ESP32-C3-WROOb4-02-N4 module performs the principal Function of wireless data transmission and reception and is therefore classifiable under CTI 8517.

CTH 851762 covers Machines for the reception, conversion and transmission or regeneration of voice. images or other data, including switching and routing apparatus. From the plain tending of thc tariff sub-heading, it appears that only those machines which independently perform all the functions of reception, conversion and transmission are covered under C’ 1’11 8517 62. Further, the HSN explanatory notes to heading 8517 (G) provides that:

(G) Other Communication apparats

This group includes apparatus which allows for the connection to a wired or wireless communication network or the transmission or reception of speech or other sounds, images or other data within such a network.

Communication networks include, inter alia, carrier-current line systems, digital-line systems and combinations thereof. They may be configured, for example, as public switched telephone networks, Local Area Networks (LAN), Metropolitan Area Networks (MAN) and Wide Area Networks (WAN), whether proprietary or open architecture.

This group includes :

(1) Network interface cards (e.g., Ethernet interface cards).

(2) Modems (combined modulators-demodulators).

(3) Routers, bridges_; hubs, repeaters and channel to channel adaptors.

(4) Multiplexers and related line equipment (e.g., transmitters, receivers or electro-optical converters).

(5) Codecs (data compressors/decompressors) which have the capability of transmission and reception of digital information.

(6) Pulse to tone converters which convert pulse dialed signals to tone signals.

The subject goods are functionally, a wireless communication apparatus, therefore, merit classification under CTH 851762. Since the subject good is not specifically covered under any specific tariff entry at the eight-digit level, it merits classification in the residual category of “Others” at eight-digit level i.e., CTH 85176290.

Further, I find that the case laws and rulings cited by the applicant are not relevant in this case, as the facts/goods are different in terms of description, technical specifications etc. The Hon’ble Supreme Court in the matter of Bhavnagar University v. Palitana Sugar Mills Pvt. Ltd.-2003(2) SCC 111 has observed that “It is well settled that a difference in facts or additional facts may take a lot of difference in the precedential value of a decision”.

23. On the basis of the literature provided by the applicant, HSN explanatory notes, Chapter note discussed above, I come to the conclusion that the subject goods contended by the applicant in the present submission, i.e. “Espressif ESP32-C3 DevKitM-1-N4X Development Board (Microcontroller Development Board)” and “SOC Product -Espressif ESP32-C3-WROOM-02-N4 Module” merit classification under Customs Tariff Heading 8517, more specifically under 8517 62 90 – Other Communication Apparatus of the First Schedule of the Customs Tariff Act, 1975.

24. The applicant has requested the Authority to keep order/ruling confidential in their application. 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 reads as:

27. Publication of orders or advance rulings Such of the order or advance ruling of the Authority deems in any other report of 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.

Accordingly, the request of the applicant to protect commercially confidential information is approved by keeping the ruling confidential.

I rule accordingly.