CESTAT Mumbai Rules GOQii Fitness Bands Not ‘Pedometers’, Classifiable as Communication Devices

April 13, 2026 : The Customs, Excise and Service Tax Appellate Tribunal (CESTAT), Mumbai has held that GOQii fitness bands and activity trackers are not mere pedometers but devices with substantial data communication capability, and therefore fall under Customs Tariff Heading (CTH) 8517 as “other communication apparatus.”

The decision was delivered by a Bench comprising Judicial Member Dr. Suvendu Kumar Pati and Technical Member M.M. Parthiban on April 13, 2026, in a dispute between the Commissioner of Customs (Import) and GOQii Technologies Private Limited. The appeal arose from an order that had earlier dropped proceedings against the company, which the Tribunal has now set aside, partly allowing the Revenue’s appeal.

The dispute concerned imports of activity trackers made between November 20, 2017 and November 15, 2019. GOQii had classified the devices under CTH 9029 as pedometers and similar instruments, attracting a lower customs duty. The department, however, contended that the products were wrongly classified and should instead fall under CTH 8517, applicable to apparatus for transmission and reception of data, which carries a higher rate of duty.

The Revenue argued that the devices are not limited to step counting but function as part of a connected ecosystem. The fitness bands pair with smartphones using Bluetooth, transmit user data to applications and servers, and enable analysis, visualization, and coaching. It was emphasized that much of the data generated becomes meaningful only after it is transmitted and processed externally, making communication capability central to the device’s function.

GOQii, on the other hand, maintained that the primary purpose of the devices is health and fitness monitoring. It pointed to features such as step tracking, heart rate monitoring, sleep analysis, blood pressure tracking, and ECG functionality, arguing that Bluetooth is only incidental and used for syncing data. The company also contended that the devices can perform their core functions independently without continuous connectivity.

After examining the technical material on record, including an expert report from IIT Bombay, the Tribunal noted that the devices are composite goods incorporating multiple components such as accelerometers, heart rate sensors, and Bluetooth modules. Applying Rule 3(b) of the General Rules for Interpretation of the Customs Tariff, the Bench held that classification must be based on the component that imparts the “essential character” of the product.

The Tribunal observed that although fitness tracking is an important feature, the devices derive significant functionality from their ability to transmit and communicate data. The Bluetooth-enabled connectivity allows integration with mobile applications and remote coaching systems, without which the broader utility of the device is substantially limited. It also noted that the products perform a wide range of functions and cannot be reduced to simple pedometers as understood under the tariff heading.

In this context, the Bench rejected the classification under CTH 9029, holding that the devices go far beyond basic step-counting instruments. Instead, considering their composite nature and reliance on data communication for full functionality, the Tribunal concluded that they are more appropriately classifiable under CTH 8517 as “other communication apparatus.”

With this finding, the Tribunal set aside the order that had dropped the demand and upheld the higher duty classification, thereby partly allowing the Revenue’s appeal.

Case Title: Commissioner of Customs (Import) vs GOQii Technologies Private Limited
Case Number: Customs Appeal No. 85064 of 2025