Door Handle “Cap Sub-Assembly” Held Classifiable as Part of Vehicle Body: CESTAT Denies 5% Concessional Duty Benefit [Read Order]

In a detailed classification ruling, the CESTAT Principal Bench, New Delhi, has held that the imported “Cap Sub-Assembly for Door Outside Handle” possesses the essential character of a finished door handle and is therefore classifiable under Customs Tariff Heading (CTH) 8708 29 00, which covers “parts and accessories of bodies” of motor vehicles.

The appellant, Aisin Automotive Haryana Pvt. Ltd. a manufacturer of car components, imported door handle cap sub-assemblies from Thailand and classified them under CTH 8708 99 00, claiming a concessional 5% Basic Customs Duty. Customs authorities later contended that the product was more appropriately classifiable under CTH 8708 29 00, as it formed part of the vehicle body. The Commissioner confirmed the duty demand and interest, leading to the present appeal.

The appellant argued that the imported product was merely an incomplete component, not capable of functioning as a door handle by itself. It required further processing—namely, insertion of a plastic base—before it could be used. Therefore, it lacked the essential character of a finished article, a precondition for classification under Rule 2(a) of the General Rules for Interpretation (GIR).

Aisin contended that the product’s principal use was as part of a handle assembly, not as a component of a car body. It therefore rightly fell under the residual heading 8708 99 00, which covers unspecified automotive parts. The appellant also cited multiple Tribunal and Supreme Court precedents, including Sony India Ltd., LG Electronics India Pvt. Ltd., and Texla Enterprises, to argue that incomplete or intermediate items cannot be treated as finished goods.

The Department asserted that the goods were specifically described as “door outside handles” in the Bills of Entry, indicating their commercial identity. Applying Rule 2(a) of the GIR, even incomplete items possessing the essential character of the finished product are classifiable as such. The small plastic attachment required did not change their fundamental nature as door handles.

Citing Section Note 3 of Section XVII and HSN Explanatory Note (B), the Department maintained that parts designed solely or principally for use with motor vehicle bodies fall under CTH 8708 29 00. Since 8708 99 00 is a residual category, it cannot apply when a specific heading exists.

The Bench held that the commercial identity of the goods was decisive. The imported items were described, marketed, and recognised in trade as door handles. Even if some components were attached post-import, they retained the essential character of a door handle.

Applying Rule 2(a) of the GIR, the Tribunal found that the imported items had the essential character of a finished door handle and were “parts of the vehicle body” under CTH 8708 29 00. It also cited the Supreme Court’s rulings in Thermax Ltd. v. CCE (2022) and Uni Products Ltd. (2020), which emphasised reliance on HSN Explanatory Notes and the principal-use test for accurate classification.

The Bench observed that the concessional notification could not apply since the product did not fall under the specified tariff heading eligible for 5% duty.

The Bench comprising Dr Rachna Gupta (Judicial Member) and Ms Hemambika R. Priya (Technical Member) concluded that the Commissioner correctly classified the imported goods under CTH 8708 29 00 and upheld the ₹1.33 crore differential duty demand along with interest. The appeal was dismissed in its entirety.

The order reaffirms that door handles and their sub-assemblies, even in unfinished form, are integral parts of vehicle bodies and not miscellaneous accessories, and that specific tariff headings take precedence over residual entries for classification purposes.

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