Sanofi India Limited Vs Commissioner of Central Excise & ST (CESTAT Ahmedabad)
Introduction: The case of Sanofi India Limited versus the Commissioner of Central Excise & ST, adjudicated by CESTAT Ahmedabad, addresses the classification of the “All Star” Reusable Insulin Delivery Device. The central question revolves around whether these devices, often referred to as syringes without needles, qualify as parts and accessories of goods under heading 9018 of the Central Excise Tariff.
Analysis: Sanofi India Limited manufactures Reusable Insulin Delivery Devices, commonly known as syringes without needles, and classified them under Central Excise Tariff Heading 9018 3100. They availed the benefit of a concessional duty rate under Notification No. 12/2012-CE. However, the Department contended that these products fell under Serial No. 309 of the same notification, attracting a nil rate of duty as parts and accessories of goods under heading 9018.
The crux of the matter lies in the interpretation of whether syringes without needles qualify as parts and accessories under Serial No. 309 or if they are standalone products entitled to a concessional duty rate under Serial No. 310 of the notification.
Sanofi India Limited argued that their product, being reusable syringes for administering insulin, should be classified under Chapter sub-heading 9018 3100, warranting a concessional duty rate of 6%. They contended that these syringes, complete and independent in themselves, do not fall under the category of parts and accessories of goods under heading 9018.
