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    LinkedIn Article by Darda Advisors LLP
    January 12, 2026 (about 1 month ago)

    Supreme Court Settles 'Parts vs. Structures' Debate and Reinforces Rule-Based Tariff Classification

    Featured image for: Supreme Court Settles 'Parts vs. Structures' Debate and Reinforces Rule-Based Tariff Classification
    India VAT News • LinkedIn Article by Darda Advisors LLP

    Summary

    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.

    Key Insights

    What did the Supreme Court rule about what constitutes a 'part' of machinery?

    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.

    Does end‑use determine tariff classification according to the ruling?

    No, end‑use is not determinative unless the tariff itself allows use‑based classification; classification is locked at import based on physical characteristics.

    What is the binding status of HSN explanatory notes in India?

    HSN explanatory notes are binding where Indian tariff entries mirror the HSN, giving them interpretive authority.

    How were aluminium shelving systems classified under the ruling?

    They were classified as structures under heading 7610, not as parts of agricultural machinery under heading 8436.

    What is the starting point for tariff classification as reaffirmed by the Court?

    The starting point is General Rule for Interpretation 1 (GRI 1), a non‑negotiable rule‑based exercise.

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