In re ONYX Components & Systems Pvt Ltd (CAAR Mumbai)
Customs Authority for Advance Rulings (CAAR) in Mumbai recently reviewed an application from ONYX Components & Systems Pvt Ltd regarding the classification of various communication modules. These modules include GSM/GPRS (2G), LTE (4G), NR (5G), NB-IoT (Narrow Band LTE 4G), and GPS Modules. The core of the applicant’s request is to classify these items under Customs Tariff Item (CTI) 85177990, which pertains to “Other” parts of apparatus for transmission or reception of voice, images, or other data.
ONYX Components & Systems Pvt Ltd, an ISO 9001:2015 certified company, imports these cellular and GPS modules for use by Original Equipment Manufacturers (OEMs). The company asserts that these modules are multi-component integrated circuits that enable internet connectivity through cellular networks or provide geolocation data via satellite networks. They emphasized that these modules are not standalone functional units. Instead, they require integration onto a Printed Circuit Board (PCB) with other components like an antenna, SIM card, and a power source to become operational within a larger device. The applicant supported their claim by referencing HSN Explanatory Notes for Heading 8517, which covers apparatus for transmission and reception of data and explicitly includes parts. They argued against classification under more general headings like 8542 (Electronic Integrated Circuits) or as complete apparatus under 85176990, stressing that the modules are integral parts, not independent machines.
