Madras HC remanded air and oil filter classification as HSN triple test was ignored by appellate authority.
The Madras High Court set aside customs classification orders on air and oil filters, holding that the appellate authority failed to apply the HSN 'triple test'—namely, language of the heading, relative specificity, and commercial reality—alongside CBIC’s internal instructions.
The court stressed that classification must be reasoned and consistent with national and international interpretive guidelines. Omission of the triple test renders decisions legally flawed and factually ungrounded.
This reinforces judicial scrutiny of technical determinations. Practitioners must ensure all three limbs of the HSN test are addressed in written submissions to strengthen appellate arguments.