The Allahabad Bench of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) has dismissed the appeal filed by the Commissioner of Customs, Noida, and upheld the classification of imported Interactive Display Systems under Customs Tariff Item (CTI) 8471 4190 as Automatic Data Processing (ADP) Machines.

The bench of Justice P.K. Choudhary (Member Judicial) and Rajeev Tandon (Member Technical) relied on the landmark Supreme Court judgment in Union of India v. Kamlakshi Finance Corporation Ltd., which emphasizes that revenue authorities must faithfully follow decisions of appellate authorities. The Supreme Court had cautioned that failure to adhere to binding precedents causes unnecessary harassment to taxpayers and creates chaos in tax administration.

The dispute revolved around the classification of Interactive Display Systems, also referred to as “Viewboards,” imported by Ingram Micro India Pvt. Ltd. These devices are used in educational institutions and corporate environments and are equipped with built-in processors, Android-based operating systems, touch-enabled interfaces, and the capability to run applications and process inputs independently.

During December 2022, the importer classified the products under CTI 8471 4190 as Automatic Data Processing Machines. However, Customs authorities disagreed and finalized the Bills of Entry by classifying the products under CTI 8528 5200, which covers display devices capable of direct connection to automatic data processing machines.

The adjudicating authority passed an Order-in-Original on July 18, 2023, confirming classification under CTI 8528 5200. The importer challenged the order before the Commissioner (Appeals), who ruled in favour of the importer and set aside the assessment order. The Revenue thereafter approached the Tribunal.

Before the Tribunal, the importer argued that the very same classification issue had already been adjudicated in its favour in earlier proceedings arising from disputes initiated at ICD Tughlakabad in 2020. In those cases, the Tribunal had categorically held through Final Order Nos. 50076-77/2022 dated February 2, 2022 that the imported Interactive Display Systems were correctly classifiable under CTI 8471 4190 and not under CTI 8528 5200.

The importer further pointed out that the Customs Department had accepted the 2022 Tribunal ruling and subsequently several similar disputes involving other importers, including Globus Infocom, BenQ India Pvt. Ltd. and Brio Interactive Technologies Pvt. Ltd., were decided on the same principles.

A major development highlighted before the Tribunal was that the Revenue’s appeals against similar Tribunal decisions in the cases of Globus Infocom and BenQ India were dismissed by the Supreme Court in 2026. The Apex Court declined to interfere with the findings of the appellate authorities and CESTAT, dismissing the civil appeals both on grounds of delay and on merits.

The importer argued that once the Supreme Court had refused to disturb the settled position on classification of identical products, the issue could no longer be reopened by departmental authorities.

After examining the records, the Tribunal observed that the classification dispute was no longer res integra and had already been conclusively settled in favour of the importer. The Bench noted that even the assessment order itself acknowledged that the products involved in the present proceedings were identical to those considered in the Tribunal’s 2022 decision.

The Tribunal held that once a higher appellate forum has decided an issue, subordinate authorities are bound to follow the decision unless it is stayed or overturned by a competent court. Re-agitating the same dispute despite binding precedent was contrary to established principles of judicial discipline.

Applying this principle, CESTAT observed that the assessment order had been passed in disregard of binding appellate rulings and therefore could not be sustained.

Concluding that the importer’s classification under CTI 8471 4190 was legally correct, the Tribunal dismissed the Revenue’s appeal and upheld the order of the Commissioner (Appeals). The ruling reinforces the settled judicial position that Interactive Display Systems possessing independent processing capabilities are classifiable as Automatic Data Processing Machines rather than merely as display devices under heading 8528.

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