CESTAT Delhi Dismisses 17 Mitsubishi Electric Appeals Over EPS-ECU Customs Classification As Automobile Part

The Principal Bench of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT), New Delhi, has upheld Customs' classification of Electronic Control Units for Electronic Power Steering (EPS-ECU) and their parts as components of automobile steering systems, dismissing 17 appeals filed by Mitsubishi Electric Automotive India Pvt. Ltd.

The tribunal held that the issue had already been settled in the company's own earlier cases involving identical goods.

A bench of Officiating President Dr. Rachna Gupta and Technical Member Hemambika R. Priya upheld the Commissioner (Appeals)' orders, holding that the imported goods were the same as those examined in the company's earlier appeals before the tribunal.

The case stemmed from imports of EPS-ECUs and their parts between April and July 2025. Mitsubishi Electric Automotive India argued that the products functioned as electronic control devices and should instead be classified under tariff entries meant for electrical control equipment or automatic regulating apparatus.

Customs, however, classified them under the tariff heading covering steering systems and their parts. The company paid the differential customs duty under protest before challenging the assessments.

The Revenue argued that the classification issue had already been decided in the company's earlier appeals involving the same products. It also pointed out that although those decisions had been challenged before the Supreme Court, no stay had been granted. The tribunal also considered the company's reliance on decisions of the Chennai Bench involving other manufacturers but found that those rulings did not govern the present dispute because they concerned different Electronic Control Units.

The tribunal observed, “Since the issue stands already decided by this Tribunal in totality of the above observations, we find no reason to differ from the earlier findings of this Tribunal and, therefore, the orders under challenge are hereby upheld.”

Accordingly, the tribunal upheld the Commissioner's orders classifying the imported goods under Customs Tariff Heading 8708 and dismissed all 17 appeals.

This uses only the tribunal's own observations in the present order, not quotations reproduced from earlier decisions.

For Appellant: Advocate Anjali Gupta

For Respondent: Ranjan Prakash and Shri Nikhil Mohan Goyal, Authorized Representatives