In re Sunwoda Electronic India Private Limited (CAAR Delhi)
Material Facts
The applicant, M/s. Sunwoda Electronic India Private Limited, manufactures lithium-ion battery packs for cellular mobile phones in a Manufacturing and Other Operations in Warehouse (MOOWR) facility established under Sections 58 and 65 of the Customs Act, 1962. For this purpose, it imports lithium-ion cells and other inputs under tariff heading 8507 60 00 by filing warehousing Bills of Entry.
At the time of filing the warehousing Bill of Entry, the applicant claimed the benefit of Serial No. 325 of Notification No. 45/2025, which provides a concessional basic customs duty rate of 10% for specified goods falling under tariff item 8507 60 00 other than those covered by Serial Nos. 322 and 324 and power banks. The applicant stated that, at the warehousing stage, it could not determine whether the manufactured battery packs would be transferred to another MOOWR unit or cleared into the Domestic Tariff Area (DTA).
For DTA clearances, the applicant proposed to claim the benefit of Serial No. 320 of Notification No. 45/2025 while filing the ex-bond Bill of Entry. Serial No. 320 provides a concessional 5% basic customs duty for lithium-ion cells used in the manufacture of batteries or battery packs for cellular mobile phones, subject to compliance with the Customs (Import of Goods at Concessional Rate of Duty or for Specified End Use) Rules, 2022 (IGCR Rules).
