Integrated medical imaging systems cannot be split into components to deny customs exemption for complete equipment.

An integrated imported medical imaging system could not be disaggregated into a single component to deny customs concession where the notification covered complete medical equipment. The invoice, catalogue and technical material showed the goods were imported and assessed as one mobile image intensifier system functioning as a single unit. On that basis, the exemption under Notification No. 21/2002-Cus. applied, and the customs challenge to the benefit failed.

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Issues: Whether an imported mobile image intensifier system, consisting of multiple integrated components, was covered by the description "Image Intensifier" in Notification No. 21/2002-Cus. so as to qualify for concessional customs duty.

Analysis: The relevant entry in the notification separately dealt with medical equipment, accessories of such equipment, and parts required for manufacture or maintenance, indicating that the covered medical equipment had to be complete in itself functionally. The imported goods were described in the invoice and catalogue as a mobile imaging system / image intensifier system, and the technical material showed that the components worked together as one integrated unit. The reasoning rejected the attempt to isolate one component and treat the goods as merely an image intensifier tube, because the system was imported and assessed as a single medical equipment meant to function in tandem.

Conclusion: The imported goods were eligible for the benefit of Notification No. 21/2002-Cus., and the departmental challenge failed.

Final Conclusion: The exemption benefit was upheld for the integrated medical imaging system, and the Revenue's appeal stood rejected.

Ratio Decidendi: Where a customs exemption entry covers a complete medical equipment, an integrated imported system functioning as a single unit cannot be disaggregated into one component to deny the concession.

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