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CAAR Holds Complete Prosthetic Joints Are Artificial Joints, Denies Customs Exemption

Case Law Details

TaxGuru Citation
2026 taxguru.in 7902
Case Name
In re Medacta India Pvt. Ltd. (CAAR Mumbai)
Date of Judgement/Order
Only available for paid members
Courts
CAAR
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In re Medacta India Pvt. Ltd. (CAAR Mumbai)

The Customs Authority for Advance Rulings (CAAR), Mumbai, considered an application seeking an advance ruling on the customs classification of various imported knee, hip, and shoulder implants and their eligibility for exemption under Serial No. 385 of Notification No. 45/2025-Customs dated 24 October 2025.

The applicant proposed to import multiple models of knee implants, hip implants, and shoulder implants under different brand names. The application described these products, their components, intended medical use, and the body parts they replace. It also stated that the implants would be imported under the required medical device licence and supplied to registered hospitals and surgical centres for use by orthopaedic surgeons.

The applicant sought rulings on two issues:

  • Whether the products should be classified under Heading 9021 as “artificial joints,” “orthopaedic appliances,” or another category under the Customs Tariff.
  • Whether the products qualified for exemption under Serial No. 385 of Notification No. 45/2025-Customs dated 24 October 2025.

In support of its application, the applicant referred to the General Rules for Interpretation, Heading 9021 of the Customs Tariff, HSN Explanatory Notes, Chapter Note 6 to Chapter 90, dictionary meanings, and judicial decisions. It submitted that the implants replace damaged body parts and should be regarded as artificial parts of the body. According to the applicant, certain products constituted artificial joints while others were classifiable as other artificial parts of the body. Alternatively, it contended that the products could also be regarded as orthopaedic appliances under tariff item 90211000.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,886

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