M/s Carestream Health India Pvt Ltdv.Commissioner of Customs

Supreme Court Holds Laser Imagers Classifiable as Accessories Under Residuary Heading, Not Diagnostic Apparatus

Case Snapshot

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

Citation: 2026 INSC 837

Bench: Justice Sanjay Kumar & Justice Sanjeev Sachdeva

Date of Judgment: August 12, 2026

Area of Law: Customs Law, Tariff Classification, Customs Tariff Act

The Judgment in One Line

Laser imagers compatible with machines under multiple tariff headings are classified under residuary CTH 9033, not under diagnostic apparatus CTH 9018.

Why This Judgment Matters

This judgment clarifies the interpretation of Rule 2(b) of Chapter 90 of the Customs Tariff Act regarding classification of accessories. The Supreme Court held that an accessory compatible with machines under different tariff headings cannot be classified under any single heading; it must fall under residuary CTH 9033. The judgment distinguishes between "parts" and "accessories" and applies the "solely or principally" test—if an accessory is compatible with machines under multiple tariff headings, it does not satisfy the test. This has significant implications for importers seeking lower duty rates by classifying accessories with diagnostic equipment.

Background

Carestream Health India Pvt. Ltd. imported "Dryview 6850 Laser Imagers W/3D" from China and classified them under CTH 9018 90 19 as "Other diagnostic instruments and apparatus." The laser imager is a printer that uses dry laser technology to develop images on film. It interfaces with digital diagnostic machines like MRI, CT, FFDM, and Digital Radiology, but has no independent diagnostic capabilities.

The Assistant Commissioner re-classified them under CTH 9033 00 00 as accessories. The Commissioner (Appeals) affirmed, and the CESTAT dismissed the appeal. The differential duty was ₹5,21,616 (2.5% higher under CTH 9033). The importer appealed to the Supreme Court.

Issues Before the Court

1. Whether imported laser imagers are classifiable under CTH 9018 90 19 as "diagnostic instruments and apparatus."

2. Whether they should be classified under residuary CTH 9033 00 00 as accessories.

3. Whether Rule 2(b) of Chapter 90 Notes applies when the accessory is compatible with machines under different tariff headings.

What Did the Supreme Court Hold?

The Supreme Court dismissed the appeal and upheld the classification under CTH 9033. The Court's reasoning was detailed:

Laser Imager Is Not Diagnostic Apparatus: The Court held that the laser imager has no diagnostic skill or capability of its own. It must receive inputs from diagnostic equipment to function. CTH 9018 90 19 applies only to "diagnostic instruments and apparatus"—the laser imager is merely a printer that transfers diagnostic data onto film.

"Parts" vs. "Accessories": The Court distinguished between parts and accessories. The laser imagers are independent of the diagnostic machines and carry out a supplementary function (printing), making them "accessories," not "parts."

Rule 2(b) of Chapter 90 Notes: The Court interpreted Rule 2(b): accessories suitable for use "solely or principally" with a particular kind of machine or with a number of machines under the same tariff heading are to be classified with such machines. Rule 2(c) provides that all other parts and accessories are classified under residuary CTH 9033.

Compatibility with Multiple Tariff Headings: The laser imagers are compatible with machines under CTH 9018 (MRI, Ultrasound) and CTH 9022 (CT, X-ray). Since they are suitable for use with machines under different tariff headings, they do not qualify under Rule 2(b). The "solely or principally" test fails.

Differential Duty Rates: The Court noted that tariff duties for machines under CTH 9018 were 7.5%, while those under CTH 9022 were 10-15%. Applying Rule 2(b) to an accessory compatible with both would create logical inconsistencies, as different rates would apply to the same accessory depending on the machine used.

Residuary Heading Applies: Being an accessory suitable for use with machines under Chapter 90 but not specified or included under a particular tariff heading, the laser imagers fall under residuary CTH 9033 00 00.

Key Legal Principles

1. Diagnostic apparatus must have independent diagnostic capability — equipment that merely prints data from diagnostic machines without independent diagnostic skills is not diagnostic apparatus.

2. "Accessory" means a part that contributes to effectiveness without changing basic function — it is an aid or addition, subordinately assisting the main equipment.

3. Rule 2(b) requires "solely or principally" with a particular kind of machine — or with a number of machines under the same tariff heading; compatibility with different headings fails the test.

4. Residuary heading applies when compatibility is across tariff headings — accessories suitable for use with machines under different headings fall under CTH 9033.

5. Different duty rates cannot be circumvented — an accessory cannot be classified to obtain a lower duty rate when it is compatible with machines under different duty rates.

6. C-Net Communication distinguished — the test of function in that case was not applicable as the decoder aided the television's performance, whereas the laser imager does not aid the diagnostic equipment's performance.

Important Precedents

Commissioner of Customs v. C-Net Communication (India) (Pvt.) Ltd., (2004) 3 SCC 639

• Distinguished: in that case, the decoder aided the television's performance; here, the laser imager does not aid the diagnostic equipment's performance—it only prints data.

Annapurna Carbon Industries Company v. State of Andhra Pradesh, (1976) 3 SCC 587

• Held that "accessories" are goods manufactured for use as an aid or addition; the same item may be an accessory of more than one kind of instrument.

Practical Impact

For advocates: This judgment is crucial when advising clients on customs classification of accessories. It establishes that accessories compatible with machines under different tariff headings cannot be classified under any single heading—they must fall under the residuary heading. The "solely or principally" test is strictly applied.

For future litigation: Importers cannot seek classification under a lower duty heading by claiming compatibility with a particular machine if the accessory is also compatible with machines under other headings. The judgment also clarifies that equipment with no independent diagnostic capability cannot be classified as diagnostic apparatus.

May be cited: In any customs classification dispute where an accessory is compatible with machines under different tariff headings, and in cases where the "solely or principally" test under Chapter 90 Notes is in question.

Lawcurb Quick Insight

The Court's application of the "solely or principally" test is significant. If an accessory works with machines under different tariff headings, it fails the test and goes to the residuary heading. This prevents importers from selecting the lowest duty heading for accessories with multiple uses.

Lawcurb Practice Note

When classifying accessories under Chapter 90, carefully examine compatibility with machines under different tariff headings. If the accessory is compatible with multiple headings, the residuary heading (CTH 9033) applies—do not attempt to classify under a single diagnostic heading.

Remember This Ratio

Accessories compatible with machines under different tariff headings are classified under residuary CTH 9033, not with any particular diagnostic heading.

Exam Lens

Q: What is the test under Rule 2(b) of Chapter 90 Notes for classifying parts and accessories? A: Rule 2(b) provides that parts and accessories suitable for use "solely or principally" with a particular kind of machine or with a number of machines under the same tariff heading are to be classified with such machines. If the accessory is suitable for use with machines under different tariff headings, it falls under residuary CTH 9033.

Q: What is the distinction between a "part" and an "accessory" for customs classification? A: A "part" is essential to the functioning of the machine and without which the machine cannot operate. An "accessory" is an aid or addition that contributes to the effectiveness of the equipment without changing its basic function. It is subordinate to the main equipment.

Q: When can equipment be classified as "diagnostic apparatus" under CTH 9018? A: Equipment can be classified as diagnostic apparatus only if it has independent diagnostic capabilities. Equipment that merely receives inputs from diagnostic equipment and prints data, without any diagnostic skill or capability, is not diagnostic apparatus.

Final Outcome

• Appeal dismissed — the Supreme Court upheld the classification under CTH 9033.

• Laser imagers classified as accessories — they are not diagnostic apparatus under CTH 9018.

• Rule 2(b) test fails — compatibility with machines under multiple tariff headings (9018 and 9022) precludes classification under any single heading.

• Residuary heading applies — CTH 9033 00 00 is the correct classification.

• Differential duty upheld — the importer is liable for the higher duty under CTH 9033.

• No costs — pending applications disposed of.

Lawcurb Verdict

This judgment is a significant clarification of customs classification rules for accessories. By holding that accessories compatible with machines under different tariff headings fall under the residuary heading, the Court has prevented importers from cherry-picking lower duty classifications. The strict application of the "solely or principally" test ensures that classification is based on objective compatibility, not selective convenience. A principled decision that upholds the tariff classification framework.

This report is prepared by Lawcurb for educational and informational purposes only. It is a concise summary of the judgment and should not be construed as legal advice. Readers are encouraged to refer to the original judgment before relying on any legal proposition.