The Supreme Court of India clarified that a 'part' of machinery must functionally participate in the machine’s operation, while structures that merely support do not qualify. It reaffirmed that tariff classification is a rule‑based exercise grounded in the Customs Tariff and HSN, and that end‑use is not determinative unless the tariff allows it. The ruling also confirmed that HSN explanatory notes carry binding interpretive value.
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Key Takeaways
The Court held that a 'part' must functionally participate in the machine’s operation; structures that merely support or hold equipment do not qualify as parts.
No, end‑use is not determinative unless the tariff itself allows use‑based classification; classification is locked at import based on physical characteristics.
HSN explanatory notes are binding where Indian tariff entries mirror the HSN, giving them interpretive authority.
They were classified as structures under heading 7610, not as parts of agricultural machinery under heading 8436.
The starting point is General Rule for Interpretation 1 (GRI 1), a non‑negotiable rule‑based exercise.
Primary source
Read full article on LinkedIn by Darda Advisors LLPThis summary was published on VATfaqs.com on 12 January 2026. It relates to VAT developments in India. The original source is LinkedIn Article by Darda Advisors LLP.