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M/s. Carestream Health India Pvt. Ltd. v. Commissioner of Customs

Civil Appeal · 2026 INSC 837Decided 12 Aug 2026
Civil Appeal No. 3440 of 2025
Justice Sanjay Kumar · Justice Sanjeev Sachdeva

Background

Carestream Health India imported "Dryview 6850 Laser Imagers" (printers that use dry laser technology to print diagnostic images (from machines like MRI, CT and ultrasound scanners) onto film) and classified them under Customs Tariff Heading (CTH) 9018 90 19 as "other diagnostic instruments and apparatus," attracting a lower duty rate. Customs authorities reclassified the imagers under the residuary CTH 9033 00 00 (unclassified parts/accessories for Chapter 90 machines), attracting a 2.5% higher duty rate and a resulting demand of Rs.5,21,616. The Assistant Commissioner, the Commissioner (Appeals), and the Customs, Excise and Service Tax Appellate Tribunal all ruled against the importer, who then appealed to the Supreme Court under Section 130E(b) of the Customs Act.

Decision Breakdown

The Court held the laser imager has no independent diagnostic capability of its own, it merely receives data from diagnostic machines and prints it onto film, so it functions as an "accessory," not a "diagnostic apparatus" in its own right, ruling out direct classification under CTH 9018. Applying Chapter 90's classification Notes, the key question was whether Rule 2(b) (accessories used "solely or principally" with machines of one tariff heading are classified with those machines) or the residuary Rule 2(c) applied. Since the imager's own sales catalogue showed it was compatible not only with machines under CTH 9018 (MRI, ultrasound scanners) but also with machines under the separate CTH 9022 (CT scanners, X-ray apparatus) (which carry different, higher duty rates) the Court held Rule 2(b) could not apply because the accessory was not tied to a single tariff heading's machines. It therefore fell into the residuary CTH 9033, as the lower authorities and Tribunal had found, and the appeal was dismissed.

Lesson Learnt

For customs classification purposes, an accessory that can be used interchangeably with machines falling under multiple different tariff headings (not just one), especially where the machines bear different duty rates, will generally be classified under a residuary "parts and accessories" heading rather than clubbed with any one machine's favorable classification: importers cannot claim the lowest applicable rate simply by asserting their product's dominant use.

Official source (sci.gov.in)View Judgment (PDF)

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