Classification of gel documentation system under heading 9027 upheld for its analytical function, not data processing.

The imported Gel Documentation and Image Analysis System was held classifiable under heading 9027 because it performed physical or chemical analysis by examining DNA and RNA and visualising molecular movement during electrophoresis. The technical literature and HSN notes showed that its essential function was analytical, not merely automatic data processing, so heading 8471 did not apply. The lower orders had failed to give proper weight to that analytical function, and the assessee's classification claim succeeded.

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Issues: Whether the imported Gel Documentation and Image Analysis System with Integrated Facility and Glossy Thermal Paper was classifiable under heading 9027 as instruments and apparatus for physical or chemical analysis, or under heading 8471 as automatic data processing machines and units thereof.

Analysis: The imported equipment was intended for analysis of DNA and RNA and for visualising the movement and separation of molecules during electrophoresis. The technical literature and the HSN notes showed that the system performed analytical functions by examining the characteristics and movement of charged particles in solution, rather than merely processing data as an automatic data processing machine. The reasoning in the lower orders had not properly accounted for the analytical function of the product.

Conclusion: The goods were correctly classifiable under heading 9027 and not under heading 8471, and the assessee's classification claim succeeded.

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