RN Chidakashi Technologies Pvt. Ltd. Vs Commissioner of Customs (CESTAT Chennai)
The Chennai Bench of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT Chennai) decided two connected appeals concerning the customs classification of the AI-powered “MIKO-3” smart robot imported by the appellant company. Although arising from separate adjudication orders, both appeals involved an identical issue and were therefore heard together and disposed of by a common order.
The appellant is engaged in the business of importing and manufacturing Automatic Data Processing Units for learning and entertainment under the brand name “MIKO.” Earlier, a basic model known as MIKO-1 had been classified under Customs Tariff Heading (CTH) 95030030. With technological advancements, the appellant introduced upgraded models MIKO-2 and MIKO-3, which were declared under CTH 84714190 as Automatic Data Processing Units (ADPU) for learning and entertainment.
For the period in dispute, the appellant imported MIKO-3 units and cleared them under CTH 84714190, claiming exemption from Basic Customs Duty (BCD) under Serial No. 8 of Notification No. 24/2005-Cus., while paying applicable IGST. Subsequent consignments of the same model were not permitted clearance by the Faceless Assessment Group, which viewed the product as an “electronic toy” classifiable under CTH 9503, attracting BCD at 60%.
