Samsung has urged Mumbai Bench of Customs, Excise and Service Tax Appellate Tribunal (CESTAT) to dismiss a $520 million tax demand over alleged misclassification of networking equipment imports, arguing that the practice was long known to tax authorities and mirrored the import approach previously adopted by Reliance Industries.

The South Korean tech major contends that Indian officials were fully aware of its classification method, which it claims followed Reliance Jio’s earlier practice of importing the same equipment without incurring tariffs between 2014 and 2017. Samsung’s challenge comes amid heightened scrutiny of foreign companies, with Volkswagen also contesting a $1.4 billion tax claim over similar issues.

In its 281-page filing before the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) in Mumbai, Samsung states that Indian authorities did not raise any objections to its imports until January 2024, when the company was asked to pay $520 million in duties for the 2018–2021 period.

Samsung asserts that it discovered, during a tax probe, that Reliance had been warned by authorities in 2017 about the classification practice. However, the company says it was never informed of this warning, nor was the classification questioned during years of similar imports.

“The classification adopted by Samsung was known to the authorities and never challenged… the Department was fully aware,” the company noted in its April 17 submission, which was reviewed by Reuters.

The details of the 2017 warning to Reliance remain confidential and were not included in Samsung’s filing. Reliance did not respond to media queries on the matter.

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