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Imported OTG Kits Missing Parts Classified as Components, Not Appliances: CAAR

Case Law Details

TaxGuru Citation
2025 taxguru.in 12072
Case Name
In re Stufa Manufacturing Enterprises (CAAR Delhi)
Date of Judgement/Order
Only available for paid members
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In re Stufa Manufacturing Enterprises (CAAR Delhi)

Stufa Manufacturing Enterprises filed an application on 3 September 2025 with the Customs Authority for Advance Rulings (CAAR), seeking clarification on the correct customs tariff classification of imported Oven Toaster Griller (OTG) spare parts and components. The applicant requested guidance on whether these imported kits should be classified as “parts” under CTH 8516.90.00 or as a complete OTG appliance under CTH 8516.60.00, citing Rule 2(a) of the General Rules for Interpretation (GRI) of the Customs Tariff. The imported goods included OTG housing, inner liner, baking and crumb trays, thermostat, timer unit, control knobs, rotisserie set, and heating elements. Certain essential components, namely the tempered glass door and power cord with plug, were sourced domestically and not included in the import. These omissions meant the imported kits could not function as a complete OTG in their imported state.

The applicant explained that the imported kits constitute the bulk of the OTG appliance but require final assembly in India, including fitting the glass door and electrical cord. The assembly process involves integrating imported parts with locally sourced components, performing electrical connections, and conducting testing and packaging. The applicant emphasized that the domestic procurement was necessary for safety, compliance with Indian standards, and cost efficiency. The shipment includes all imported components in a single consignment for each batch, with no intent to split or evade duties.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,887

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