Supreme Court of India· 12 August 2026

Under the Customs Tariff Act, 1975, can imported laser imagers that interface with diagnostic machines like MRI and CT scanners but possess no independent diagnostic skill or capability be classified as 'diagnostic apparatus' under CTH 9018 90 19?

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

2026 INSC 837 · Civil Appeal No. 3440 of 2025
Coram: Sanjay Kumar; Sanjeev Sachdeva

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Answer

No. Since 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, it is an accessory to such equipment and cannot be classified as a diagnostic apparatus in its own right under CTH 9018 90 19.

Headnote

Customs Tariff Act, 1975 — CTH 9018 90 19 — CTH 9033 00 00 — Chapter 90, Note 2 — Rule 2(b) — Rule 2(c) — Accessory — Solely or principally — Customs Tariff Act, 1975 — CTH 9018 90 19 — Diagnostic apparatus — Accessory, not apparatus — Held: 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; it is, therefore, an accessory to such equipment and cannot be classified under CTH 9018 90 19 as a diagnostic apparatus in its own right. (¶8, 9) Customs Tariff Act, 1975 — Chapter 90, Note 2(b) — Solely or principally — Different tariff headings — Held further: Rule 2(b) applies only where an accessory is suitable for use solely or principally with machines of a particular tariff heading; since the laser imagers are compatible with machines falling under both CTH 9018 and CTH 9022, Rule 2(b) cannot apply and residuary CTH 9033 00 00 alone is attracted under Rule 2(c). (¶16, 17) Customs Tariff Act, 1975 — CTH 9033 00 00 — Appeal dismissed — Held further: The interpretation placed upon Rule 2(b) by the Tribunal was valid and correct, and the appeal against classification of the laser imagers under residuary CTH 9033 00 00 was bereft of merit and dismissed. (¶18, 19)

In the Court's own words

Paragraph 8At the outset, we are not persuaded to agree with the appellant’s contention that the laser imager is a ‘diagnostic apparatus’ in its own right. 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. In effect, it is an ‘accessory’ to the diagnostic equipment from which it receives inputs, as it then transfers the same onto films. CTH 9018 90 19 admittedly applies only to ‘other diagnostic instruments and apparatus’, i.e., either ‘diagnostic instruments’ or ‘diagnostic apparatus’. As the laser imager has no diagnostic capabilities of its own, it cannot per se be classified under this heading.

Paragraph 9Commissioner of Customs, New Delhi vs. C-Net Communication (India) (Pvt.) Ltd.[^1] is of no avail to the appellant. The issue in that case was whether a signal decoder was ‘reception apparatus for television’ or whether it was classifiable as ‘electrical machines and apparatus having individual functions’. Noting that, even without a decoder, a television would work, this Court observed that the true test is as to the function that the decoder achieves in the use of the television. Applying this test, it is clear that the laser imager does not aid in or augment the performance of the medical equipment that it receives inputs from. It only plays the ancillary function of transferring such inputs onto film for preservation or further use by medical professionals. The medical equipment that carries out the diagnostic function is complete in itself and the laser imager does not contribute in any manner to that exercise. In effect, it only serves as an accessory to such medical equipment by printing the transmitted diagnostic data on films.

Acts & Sections

s.130E(b) Customs Act, 1962CTH 9018 90 19 Customs Tariff Act, 1975CTH 9033 00 00 Customs Tariff Act, 1975Ch.90 Note 2 Customs Tariff Act, 1975

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Also decided in this judgment

Under Note 2(b) to Chapter 90 of the Customs Tariff Act, 1975, can an accessory compatible with machines falling under two different tariff headings still be classified with either heading under the 'solely or principally' rule?This Court in Commissioner of Customs, New Delhi v. C-Net Communication (India) (Pvt.) Ltd. classified a signal decoder by the test of the function it achieves in the use of the main apparatus — does that test assist an importer seeking to classify a laser imager as diagnostic apparatus rather than an accessory?Can an importer rely for the first time before the Supreme Court on an exemption notification without having established foundational compliance with its conditions at any earlier stage?

Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections