In re Lab Medica Systems Private limited (GST AAR Gujarat)
The Gujarat Authority for Advance Ruling considered an application filed by M/s. Lab Medica Systems Private Limited, a supplier of Ophthalmic Binocular Surgical Microscopes. The applicant sought an advance ruling on whether the product should be classified under Customs Tariff Heading (CTH) 9018 of the First Schedule to the Customs Tariff Act, 1975 and whether it would fall under Entry No. 483 of Schedule I of Notification No. 09/2025-Central Tax (Rate) dated 17.09.2025.
The applicant described the Ophthalmic Binocular Surgical Microscope as a specialised instrument used exclusively by ophthalmic surgeons for examination and surgery on the anterior and posterior segments of the eye. It submitted that the instrument provides a magnified three-dimensional stereoscopic view, incorporates features such as bright red reflex, motorised zoom, electromagnetic locking system, independent assistant microscope, wide-angle fundus viewing system, integrated imaging and specialised illumination, and is used in procedures including cataract, corneal, retinal, glaucoma, vitreoretinal and other ophthalmic surgeries.
The applicant contended that the product was specifically designed for medical and surgical use and therefore merited classification under CTH 9018 rather than CTH 9011 or 9012. It relied upon the HSN Explanatory Notes, which describe ophthalmic instruments under Heading 9018 and state that ophthalmic binocular-type microscopes are excluded from Heading 9011. The applicant further submitted that microscopes under Headings 9011 and 9012 are general-purpose instruments used by amateurs, teachers, industrial users and research laboratories, whereas the product in question is designed exclusively for ophthalmic surgery. It also referred to Rule 3 of the General Rules for Interpretation, submitting that the specific heading should prevail over a general heading.
