Accessories Compatible With Multiple Machines Across Different Tariff Headings Cannot Claim Benefit Of Rule 2(b) And Attract Residuary CTH 9033: Supreme Court

"When it speaks of accessories suitable for use ‘solely or principally’ with a particular kind of machine or a number of machines of the same tariff heading, Rule 2(b) clearly distinguishes and separates such accessories from those suitable for use with a number of machines falling under different tariff headings." Supreme Court, in a significant ruling dated August 12, 2026, held that laser imagers compatible with medical equipment falling under separate tariff headings cannot be classified under residuary provisions meant for specific medical instruments, attracting instead the general residuary heading CTH 9033.

A bench of Justices Sanjay Kumar and Sanjeev Sachdeva observed that invoking Rule 2(b) of Chapter Notes defies logic when an accessory serves machinery spanning multiple distinct tariff classifications carrying different rates of duty.

The appellant, M/s. Carestream Health India Pvt. Ltd., imported 'Dryview 6850 Laser Imagers W/3D' from China and sought classification under Customs Tariff Heading 9018 90 19 as diagnostic apparatus. The Revenue authorities rejected this classification, directing re-classification under CTH 9033 00 00 as accessories not specified elsewhere. Concurrent adverse findings by the original authority, the Commissioner (Appeals), and the Customs, Excise and Service Tax Appellate Tribunal led the importer to approach the Apex Court under Section 130E(b) of the Customs Act, 1962.

The primary question before the court was whether imported laser imagers possessing no independent diagnostic capabilities qualify as diagnostic instruments or apparatus under CTH 9018. The court was also called upon to determine whether such multi-compatible accessories attract Chapter 90 Note 2(b) for classification under CTH 9018 or fall under the general residuary heading CTH 9033 pursuant to Rule 2(c).

Laser Imagers Lack Independent Diagnostic Skills

The bench noted at the outset that the imported laser imager is fundamentally a printer utilizing photo thermographic technology to develop images on film. It interfaces with various digital diagnostic machines like MRI, CT, and Ultrasound Scanners but possesses no independent diagnostic skills or capabilities. The court observed that it is not medical equipment in its own right and cannot be classified per se under CTH 9018 90 19 which strictly applies to diagnostic instruments or apparatus.

"Admittedly, the laser imager has no diagnostic skill or capability of its own and must necessarily receive inputs from diagnostic equipment to carry out its function of printing films."

No Augmentation of Performance Under Cth 9018 Court Applies Functional Test From C-Net Communication Precedent

Distinguishing the precedent in Commissioner of Customs v. C-Net Communication (India) (Pvt.) Ltd., the court emphasized that the laser imager does not aid or augment the performance of medical equipment. It merely plays the ancillary function of transferring inputs onto film for preservation, serving strictly as an accessory rather than a contributor to the core diagnostic exercise.

"It only plays the ancillary function of transferring such inputs onto film for preservation or further use by medical professionals."

Application of Chapter Note 2 To Accessories Chapter Note Rules Determine Classification Avenue

Since the laser imagers do not directly fall under CTH 9018, their classification as accessories must be governed by the Notes in Chapter 90 of the Customs Tariff Act, 1975. The court examined Note 2, which dictates that Rule 2(a) applies to goods included in specific headings, while Rule 2(b) covers parts and accessories suitable for use solely or principally with a particular machine or machines under the same heading.

"The laser imagers are obviously not ‘parts’ of the diagnostic machines used for medical imaging as they are independent of such machines but they are ‘accessories’ thereto."

Compatibility Across Multiple Tariff Headings Catalogues Reveal Compatibility With CTH 9018 And CTH 9022

Referring to the appellant's own product catalogues, the court noted that the laser imagers are compatible not only with equipment falling under CTH 9018 like ultrasound scanners and MRI apparatus but also with X-ray and CT equipment falling under CTH 9022. Citing the three-judge bench decision in Annapurna Carbon Industries Company v. State of Andhra Pradesh, the court reiterated that accessories often serve as aids to multiple kinds of instruments.

"The issue, therefore, boils down to whether the laser imagers, which are compatible with machines falling under separate tariff headings, i.e., 9018 and 9022, would still qualify under Rule 2(b)."

Defies Logic To Apply Rule 2(b) Across Different Duty Rates Varying Tariff Duties Rule Out Consolidation Under One Heading

The bench reasoned that Rule 2(b) clearly distinguishes accessories suitable for use with machines of the same tariff heading from those usable across different headings. Highlighting that disparate tariff duties applied to CTH 9018 apparatus versus CTH 9022 equipment at the relevant time, the court concluded that forcing such multi-compatible accessories into Rule 2(b) would defy logic and statutory intent.

"In such a scenario, it defies logic and rationale to invoke Rule 2(b) for application to an accessory that may be clubbed with machines falling under CTH 9018 and also CTH 9022."

Tribunal's Interpretation Upheld Residuary CTH 9033 Attracted For Multi-Heading Accessories

Affirming the correctness of the tribunal's view, the Supreme Court held that when accessories are suitable for use across multiple tariff headings, they necessarily fall under residuary CTH 9033 00 00. The appellant's belated reliance on Notification No. 12/2012 was rejected for failure to establish foundational compliance with prescribed conditions before lower forums.

The Supreme Court dismissed the civil appeal, upholding the concurrent findings that multi-compatible accessories spanning different tariff headings must fall under the residuary CTH 9033 00 00. The ruling provides clarity on the strict interpretation of Chapter Note 2(b) regarding multi-functional medical accessories under the customs regime.

Date of Decision: 12 August 2026