Telephone-system accessories that only record call data are not classifiable as line telephony apparatus under Heading 8517.

Programming EPROMs used in STD/PCO equipment did not make the goods classifiable as electronic apparatus for line telephony under Heading 8517.00 because the equipment only measured call duration, calculated charges, and displayed call details; it did not itself perform line telephony or telegraphy. The Explanatory Notes for Heading 85.17 covered telephone sets and integrated telephone devices, not a device that merely assisted a telephone booth system. The programmed EPROMs were treated as, at most, an adjunct rather than a part or accessory of the telephone system, so the duty demand based on Heading 8517.00 was not sustainable.

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Issues: Whether the activity of programming EPROMs used in STD/PCO equipment rendered the goods classifiable under Heading 8517.00 of the tariff, and whether the resultant duty demand could be sustained.

Analysis: The equipment in question was used to measure call duration, calculate charges, and display call details, but it did not itself perform line telephony or telegraphy. The Explanatory Notes relied upon for Heading 85.17 covered telephone sets and integrated telephone devices, but did not support treating a device that merely assists in the functioning of a telephone booth system as an apparatus for line telephony. The programmed EPROMs were found to be, at most, an adjunct to the telephone system and not a part or accessory of it. The claimed alternative classification under Heading 85.24 was not examined on merits.

Conclusion: Classification under Heading 8517.00 was not sustainable and the duty demand based on that classification failed; the appeal was allowed in favour of the assessee.

Ratio Decidendi: A device that only assists in measuring, recording, or displaying telephone call data, without itself constituting apparatus for line telephony, is not classifiable as electronic apparatus for line telephony under Heading 8517.

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