Case Law Details
Philips India Limited Vs Commissioner of Customs (Air Cargo) (CESTAT Chennai)
The case of Philips India Limited vs Commissioner of Customs (Air Cargo) was brought before the CESTAT Chennai concerning the classification and eligibility for duty exemption of imported goods. The appellant contended that the goods were accessories to MRI machines and thus eligible for concessional rates.
The appellant had imported goods declared as “Sonalleve MR HIFU KIT (Accessories for MRI system)” and claimed concessional rates of duty. The dispute arose when the department alleged incorrect availing of benefits under relevant notifications. The appellant argued that the goods were indeed accessories to MRI machines, citing legal precedents and functional dependence on MRI technology.
The classification of the goods under CTI 90181300, which pertains to Magnetic Resonance Imaging apparatus (MRI), was crucial. Note 2 (b) to Chapter 90 specifies that parts and accessories suitable for use solely or principally with a particular machine should be classified with that machine. The appellant’s claim that the goods could only be used with Philips MRI machines was significant.
CESTAT Chennai examined previous rulings and analogies, such as the case of Manipal Academy of Higher Education vs. Commissioner of Customs, to determine the accessory status of the goods. It emphasized the functional interdependence of the imported goods with MRI machines, akin to accessories identified in other medical equipment.
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