Toner cartridges as printer parts qualify for nil duty when they are integral to the printing mechanism.

Toner cartridges imported for use in computer printers were treated as parts of machines of heading 8471, not mere accessories, because the printer could not function without them and the cartridge was integrally connected with the printing mechanism. On that functional and tariff-based analysis, the part-accessory distinction did not justify denial of the exemption, and the goods were eligible for nil duty under Notification No. 21/2002-Cus., as amended.

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Issues: Whether toner cartridges imported for use in computer printers were classifiable as parts of machines of heading 8471 so as to qualify for nil duty under Notification No. 21/2002-Cus. as amended, or were merely accessories and therefore outside the exemption.

Analysis: The imported toner cartridge was admittedly meant for use in a computer printer and the printer could not function without it. On that factual and functional basis, the cartridge was integrally connected with the printing mechanism and could not be treated as a mere accessory. The tariff heading itself covered parts and accessories of machines of heading 8471, and the named sub-classifications did not support denying exemption merely by labelling the item an accessory. The part-accessory distinction, in the context of the tariff entry and the exemption notification, did not justify refusal of the benefit to the imported goods.

Conclusion: The toner cartridge was held to be a part of the computer printer and eligible for the nil duty benefit under the notification.

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