Activity of mere Loading software in a device does not amount to manufacture – AAR

CA Urvashi Porwal Brief Facts M/s Nucleus Software Exports Limited (hereinafter also referred to as applicant) is a Public Limited Company resident in India. Applicant proposes to import a hardware product called the Nucleus Device manufactured by a Chinese entity. Applicant proposes to undertake the activity of loading of business software on said Nucleus Device. Nucleus Device is classifiable under Tariff Entry 85176290 of the First Schedule to the Central Excise Tariff Act, 1985 as Machines for the reception, conversion and transmission or regeneration of voice, images or other data, includ...