Medical use did not settle the tariff heading
Carestream argued for Heading 9018 90 19, covering the identified category of diagnostic instruments and apparatus. The Revenue treated the devices as accessories falling under 9033 00 00. The Court focused on function: the imager had no diagnostic capability of its own and transferred diagnostic inputs onto film. The equipment performing diagnosis was complete without it. That distinction was more important than the fact that both devices were used in healthcare. (Paragraphs 8–9.)
Compatibility across headings mattered
The Chapter 90 notes distinguish accessories suitable solely or principally for the relevant machines from accessories used with machines across different tariff headings. The imagers could receive inputs from equipment under both 9018 and 9022. The Court upheld the tribunal’s reading that the residual heading applied in this setting, rather than attaching the accessory to one selected machine heading despite its wider use. (Paragraphs 11 and 15–18.)
The exemption argument had a separate difficulty
Carestream also invoked Notification No. 12/2012 before the Supreme Court. The Court noted both the tariff headings specified in the notification and the need to establish compliance with its conditions. The notification did not include the residual heading at issue, and the necessary foundational case had not been made earlier. Medical use alone was not treated as sufficient to secure the claimed concession. (Paragraph 10.)
How to read the outcome responsibly
The appeal was dismissed. The decision concerns the characteristics of these imported goods and the tariff provisions examined in the dispute. It does not classify every medical printer, accessory or later product model, and the historical duty rates discussed should not be presented as a current import-price guide. The useful inquiry is the product’s actual function, its relationship with the principal equipment and the precise chapter notes. (Paragraphs 8–19.)
A question this judgment answers
Was the imager itself a diagnostic apparatus?
The Court held that it was not: it had no diagnostic capability and printed data supplied by separate diagnostic equipment. (Paragraphs 8–9.)
Lawyers and appearances recorded by SCR
The following retains the source’s grouping and designations. It does not establish each lawyer’s role in every connected proceeding.
- Advs. for the Appellant(s):
- Ms. Charanya Lakshmikumaran, L. Badri Narayanan, Ms. Neha Choudhary, Ms. Nitum Jain, Ms. Medha Sinha, Swastik Mishra, Adithya Nair, Yashovardhan Singh.
- Advs. for the Respondent(s):
- Raghvendra P. Shankar, A.S.G., Gurmeet Singh Makker, B.K. Satija, Adarsh Kumar Pandey, Ms. Pallavi Mishra, Ms. Rajeshwari Shankar.
Procedural origin recorded by SCR
CIVIL APPELLATE JURISDICTION: Civil Appeal No. 3440 of 2025
From the Judgment and Order dated 21.08.2024 of the Customs Excise and Service Tax Apellate Tribunal, South Zonal Bench, Chennai in CA No. 41073 of 2014