Storage Servers Manufactured by Sanmina-SCI India: CAAR Mumbai Rules on Classification and Duty Exemption Under Notification No. 24/2005-Customs
Background and Context
The Customs Authority for Advance Rulings (CAAR), Mumbai, issued its ruling in Ruling No. CAAR/MUM/ARC/102, 103/2026-27 dated 06.10.2026 in the matter of In re Sanmina-SCI India Private Limited, addressing two critical questions: the correct customs tariff classification of five distinct storage server models, and whether imported manufacturing inputs used to produce these servers qualify for a Nil rate of Basic Customs Duty under Serial No. 39 read with Serial No. 8 of Notification No. 24/2005-Customs dated 01.03.2005.
Sanmina-SCI India Private Limited, a contract electronics manufacturer incorporated in India with its registered office at 1, SIPCOT Industrial Growth Centre, Mathur Village, Oragadam, Chennai 602105, holds IEC No. 0403030714. The company is a joint venture involving Reliance Strategic Business Ventures Limited and Sanmina-SCI Systems Singapore Pte. Ltd., with the broader Sanmina Group operating across 21 countries. The applicant sought the advance ruling in connection with proposed future imports of components and sub-assemblies intended for the manufacture of the five storage server models described in its application.
The Five Storage Server Models Under Consideration
The advance ruling application covered the following products:
- VDS41022 Enterprise SAS-4 High Density High Availability JBOD ("Crestone Model-1")
- Turnkey VDS41022 JBOD ("Crestone Model-2")
- VSS2249RQ 2U 24 NVMe PCI Gen 4 drive Storage Server ("La Jolla")
- VSS2320 2U NVMe PCIe 5.0 High Availability Shared Storage Server ("Coronado")
- NSS2561-CS-09 ("Mlk Mavericks")
Functional Overview of Each Model
Crestone Model-1 and Crestone Model-2
Both models are high-density JBOD (Just a Bunch of Disks) enclosures capable of housing up to 102 SAS/SATA drives. They interface with host systems via 24 Gb/s SAS-4 ports and incorporate dual I/O controller modules that offer failover functionality. SCSI Enclosure Services (SES 3.0) firmware facilitates monitoring and diagnostics. Critically, neither model possesses an onboard general-purpose processor capable of independently executing user programs. Their operation is entirely dependent on an external host automatic data processing (ADP) system, making them purely passive storage peripherals.
La Jolla (VSS2249RQ)
This 2U rack-mount server integrates two server modules, each containing an AMD EPYC Milan CPU, four x16 PCIe Gen 4 slots, and up to 8 DIMMs. It supports up to 24 NVMe drives with dual-port connections, IPMI and Redfish firmware management interfaces, and dual redundant 1600W power supply units.
Coronado (VSS2320)
This model is powered by dual AMD EPYC 4th generation processors, supports 32 hot-pluggable EDSFF E3.S SSDs using PCIe Gen 5 NVMe technology, and incorporates up to 6 TB of DDR5 memory with four PCIe Gen 5 slots per server module. Management tools include OpenBMC, IPMI, and Redfish interfaces.
Mlk Mavericks (NSS2561-CS-09)
This product functions as a high-capacity storage and compute platform supporting up to 56 NVMe U.2 drives connected via Gen 3 x2 PCIe interfaces, with two PCIe slots for HHHL add-in cards, NVDIMMs support, and individual power control per drive slot. The system is designed for enterprise-level deployments requiring high throughput and sustained performance.
Imported Inputs: Materials Proposed for Import
The applicant proposed to import a wide range of electronic and mechanical components for use in manufacturing the above servers. These included:
- PCBs and PCB sub-assemblies
- Integrated circuits (ICs), digital ICs, IC logics, IC linear
- Capacitors, resistors, transistors, diodes, MOSFETs
- Connectors, sockets, switches, filters
- Memories, NVDIMMs, oscillators, crystals, frequency control devices
- Heat sinks, standoffs, ferrite beads, inductors
- Sheet metal parts, machined metals, plastics, fasteners, screws, nuts
- Cable harnesses and assemblies, fans, batteries
- Power supplies and regulators, LED components, optoelectronics, RF devices, magnetics, fuses, inks
Manufacturing Process
The production process undertaken by the applicant was described in detail and comprised the following stages: