Samsung has approached the Customs Excise and Service Tax Appellate Tribunal in Mumbai to contest a $520 million tax demand, arguing that Indian authorities were fully aware of its import classification practices, which mirrored Reliance Jio’s historical methods.
The case pertains to the alleged misclassification of “Remote Radio Head” units, crucial 4G telecom components, imported from Korea and Vietnam between 2018 and 2021. Indian tax officials claim Samsung evaded 10–20 per cent tariffs, selling the equipment to Reliance Jio. In addition to the $520 million duty, an $81 million penalty has been levied on seven Samsung employees, taking the total demand to $601 million.
In its filing, Samsung had asserted that the tax department was aware Reliance Jio followed a similar import model for years until 2017, and that Samsung was neither warned nor questioned at the time. The company also alleged that the January tax order was rushed, denying it a fair hearing despite the high financial stakes, especially given that the tax claim amounts to over 60 per cent of its 2023 net profit of $955 million in India.
The company maintains that the classification of the telecom equipment was consistent with past industry practice and is seeking to have the order overturned.
