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Legal Review and Analysis of M/s Carestream Health India Pvt Ltd vs Commissioner of Customs 2026 INSC 837

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


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