CESTAT Delhi Upholds Correct Classification of Imported Vehicles

Date: 03.10.2025

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.

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. ​ 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. ​

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. ​This reclassification led to a demand for differential customs duty of Rs. ​ 41,61,609, along with penalties and fines. ​ Polaris India challenged this decision, asserting that their vehicles were primarily designed for transporting goods and performing utility functions.

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