Laptop computers are not a CPU-monitor-keyboard set for additional duty; integrated units fall outside the rule.

Laptop computers are not covered by Rule 2 of the Computer (Additional Duty) Rules, 2004 as a "CPU with monitor, mouse and keyboard imported together as a set" because a notebook or laptop functions as a complete, integrated and inseparable unit. The rule applies to separately identifiable items brought together to make a computer, not to a single laptop whose components have lost separate identity in trade parlance. On that basis, the department's classification was unsustainable and additional duty was not leviable; the assessee succeeded and the impugned assessment was set aside.

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Issues: Whether laptop computers are covered by the expression "CPU with monitor, mouse and keyboard imported together as a set" under Rule 2 of the Computer (Additional Duty) Rules, 2004 and are therefore liable to additional duty at 7%.

Analysis: The imported goods were notebook or laptop computers, which function as a single inseparable unit with the relevant components integrated into one system. The rule applies to a set of separately identifiable items brought together to make a computer, not to a complete laptop whose individual components have lost separate identity. In trade parlance, a laptop is understood as a complete computer and not as a set of CPU, monitor, keyboard and mouse. Accordingly, the classification adopted by the department was not sustainable.

Conclusion: Laptop computers are not covered by Rule 2 of the Computer (Additional Duty) Rules, 2004 as a set of CPU, monitor, mouse and keyboard, and additional duty is not leviable. The assessee succeeds and the Revenue appeal fails.

Final Conclusion: The impugned assessment on laptop computers was set aside, and the exemption from additional duty was upheld.

Ratio Decidendi: A complete laptop computer, being an integrated and inseparable unit, cannot be treated as a separately imported set of CPU, monitor, mouse and keyboard for the purpose of levy of additional duty under the relevant rules.

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