The Supreme Court has upheld the classification of imported laser imagers under Customs Tariff Heading (CTH) 9033 00 00, holding that accessories capable of use with machines falling under different tariff headings cannot be classified along with machines under a single heading.
A Bench comprising Justice Sanjay Kumar and Justice Sanjeev Sachdeva delivered the judgment on August 12, 2026, in Civil Appeal No. 3440 of 2025. The Court dismissed the appeal filed by M/s. Carestream Health India Pvt. Ltd. against the Commissioner of Customs.
Background of the Case
The dispute concerned the classification of “Dryview 6850 Laser Imagers W/3D” imported from China under a Bill of Entry dated April 2, 2013.
The importer had classified the equipment under CTH 9018 90 19 as “other diagnostic instruments and apparatus”. Customs authorities rejected that classification and directed its reclassification under CTH 9033 00 00, which covers certain parts and accessories of machines, instruments and apparatus falling under Chapter 90.
The Commissioner of Customs (Appeals) upheld the decision. The Customs, Excise and Service Tax Appellate Tribunal, Chennai, also dismissed the importer’s appeal in August 2024. The dispute eventually reached the Supreme Court.
The classification carried a 2.5% difference in the applicable duty rate at the relevant time, resulting in a differential duty demand of ₹5,21,616.
Supreme Court's Observation
The Court noted that the laser imager functions as a printer using dry laser technology to transfer images onto film. It can receive inputs from MRI, CT, digital radiology, mammography and other diagnostic systems.
However, the Bench rejected the argument that the laser imager itself was a diagnostic apparatus.
The Court observed that the machine “has no diagnostic skill or capability of its own” and receives inputs from diagnostic equipment before printing them on film. Therefore, it functioned as an accessory rather than an independent diagnostic instrument.
The Bench further examined Note 2 to Chapter 90 of the Customs Tariff. Under Rule 2(b), an accessory suitable for use solely or principally with a particular kind of machine, or machines falling under the same tariff heading, can be classified with those machines.
The Court found that the laser imagers could be used not only with equipment under CTH 9018 but also with machines under CTH 9022, including CT scanners and X-ray equipment.
Court's Decision
The Supreme Court held that Rule 2(b) could not apply where an accessory was suitable for machines falling under different tariff headings. In such circumstances, Rule 2(c), which directs classification under CTH 9033, would apply.
“The appeal is bereft of merit and is dismissed accordingly,” the Bench held. Pending applications were also disposed of.
The Court accordingly upheld the Tribunal’s classification of the imported laser imagers under CTH 9033 00 00.
Case Details:
Case Title: M/s. Carestream Health India Pvt. Ltd. v. Commissioner of Customs
Case Number: Civil Appeal No. 3440 of 2025
Judge: Justice Sanjay Kumar and Justice Sanjeev Sachdeva
Decision Date: August 12, 2026
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