ALO Law Office- IDT Tax I Arbitration I Litigation
Date: 24.07.2025
Supreme Court Clarifies Scope of Rule 2(a) in Customs Classification
The Supreme Court of India in Commissioner of Customs, New Delhi v. Sony India Ltd., has dismissed the Customs Departmentโs appeal and upheld the decision of the CESTAT in favor of Sony India Ltd., clarifying the application of Rule 2(a) of the General Rules for the Interpretation of the Customs Tariff.
Background of the Case
The case revolved around the importation of various components of Colour Television (CTV) models by Sony India Ltd. between 1995 and 1997. The Customs authorities alleged that Sony had effectively imported Complete CTV Sets in Completely Knocked Down (CKD) form, but declared them as mere components to avail concessional duty.
The Commissioner of Customs, relying on Rule 2(a) of the Interpretative Rules, clubbed the 94 consignments of parts imported over 22 months and treated them as complete CTVs, thereby raising a massive differential duty demand of โน42.89 crores, with penalties of โน30.19 crores under Sections 112 and 114 of the Customs Act, 1962.
This Article has been written by Shri Ravi Shekhar Jha, Advocate Delhi High Court based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com or on his Mobile +91-9999005379.
Source: Supreme Court of India
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