
ALO Law Office- IDT Tax I Arbitration I Litigation
Date: 03.10.2025
CESTAT Delhi Upholds Correct Classification of Imported Vehicles

This Article has been written by Shri Ravi Shekhar Jha, Advocate based in New Delhi. The views expressed are based on his interpretation of the law. He can be reached at his email id intelconsul@gmail.com or on his Mobile +91-9999005379.
In a significant victory for Polaris India Private Limited, the Customs, Excise & Service Tax Appellate Tribunal (CESTAT), New Delhi, has ruled in favor of the company in a long-standing dispute over the classification of its imported vehicles. The case, which revolved around the classification of Polaris’ Ranger (non-electric), Ranger (electric), and Brutus vehicles, has been a contentious issue since 2019. The tribunal’s decision, delivered on July 3, 2023, sets a precedent for the interpretation of customs classifications for specialized vehicles.
The Background of the Case
Polaris India, a wholly-owned subsidiary of Polaris Industries Inc., USA, imports All-Terrain Vehicles (ATVs) and other off-road vehicles designed for utility purposes. β Between 2013 and 2016, Polaris imported several models, including the Ranger (non-electric), Ranger (electric), and Brutus vehicles, classifying them under Customs Tariff Headings (CTH) 8704 and 8709, which pertain to vehicles designed for the transportation of goods. β
However, the Principal Commissioner of Customs (Import), New Delhi, reclassified these vehicles under CTH 8703, which covers motor vehicles principally designed for the transportation of persons. βThis reclassification led to a demand for differential customs duty of Rs. β 41,61,609, along with penalties and fines. β Polaris India challenged this decision, asserting that their vehicles were primarily designed for transporting goods and performing utility functions.
Source: CESTAT Delhi
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