Laptops are not a set of CPU, monitor, mouse and keyboard; additional customs duty was held inapplicable.

A laptop or notebook computer is not classifiable as a CPU with monitor, mouse and keyboard imported together as a set for the purpose of Rule 2 of the Computers (Additional Duty) Rules, 2004. The levy under section 3(3) and section 3(4) of the Customs Tariff Act applies only to goods that answer the commercial description of distinct computer components imported together; an integrated laptop is marketed and understood as a single inseparable unit. Section 19 of the Customs Act supports the distinction between a true set of articles and a single composite product, and the taxing entry must be construed strictly. Accordingly, additional duty at 7% was not leviable on laptops.

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Issues: Whether notebook computers or laptops are classifiable as a CPU with monitor, mouse and keyboard imported together as a set under Rule 2 of the Computers (Additional Duty) Rules, 2004 so as to attract additional duty at 7% ad valorem.

Analysis: The levy under section 3(3) and section 3(4) of the Customs Tariff Act is intended to counter-balance excise duty and is applied through the specific classification in Rule 2 of the Computers (Additional Duty) Rules, 2004. The relevant entry covers only a combination of a CPU with monitor, mouse and keyboard imported together as separate but complementary items. Applying the commercial parlance test, a desktop or micro computer may answer that description, but a laptop is marketed and understood as an integrated, inseparable unit and not as a set of distinct components. Section 19 of the Customs Act, which deals with a set of articles, also supports the distinction between a true set of identifiable articles and a single integrated product. As the rule is a taxing provision, it must be construed strictly.

Conclusion: A laptop or notebook computer is not a CPU with monitor, mouse and keyboard imported together as a set, and the additional duty at 7% was not leviable on the imported goods.

Ratio Decidendi: For levy under a taxing entry covering a "set" of computer components, only goods that are commercially and structurally distinct constituent articles imported together can be treated as such; an integrated laptop or notebook computer cannot be equated with a desktop-style set of CPU, monitor, mouse and keyboard.

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