Functional classification of X-ray imaging equipment determined exemption eligibility and separated medical devices from accessories.

Classification turned on each product's primary function and technical operation. FCR Capsula was treated as an independent apparatus processing X-ray images already captured on an image plate, so it fell under heading 9022 and was outside the claimed exemption. Dry Pix 7000 was regarded as a medical-use printer for X-ray images, not a general-purpose printer, and was also classified under heading 9022 without exemption. IP cassettes and imaging plates were treated as media and components used for X-ray exposure in computed radiography, so they were classified under heading 9018 and satisfied the exemption conditions.

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Issues: (i) Whether FCR Capsula was classifiable as an independent apparatus under heading 9022 and therefore outside the scope of the claimed exemption; (ii) whether Dry Pix 7000 was classifiable under heading 9022 and eligible for the claimed exemption; (iii) whether IP Cassettes and Imaging Plates were classifiable under heading 9018 and eligible for exemption as accessories.

Issue (i): Whether FCR Capsula was classifiable as an independent apparatus under heading 9022 and therefore outside the scope of the claimed exemption.

Analysis: FCR Capsula processed the X-ray image already captured on the image plate and did not operate on X-rays as an input. It functioned as an independent apparatus rather than an X-ray based device. On that reasoning, it fell under heading 9022 and did not answer the description for exemption under the claimed notification.

Conclusion: Against the assessee.

Issue (ii): Whether Dry Pix 7000 was classifiable under heading 9022 and eligible for the claimed exemption.

Analysis: Dry Pix 7000 was found to be a medical-use instrument that printed X-ray images obtained on imaging plates and could not be used for general-purpose printing. As it contributed to the defined function of X-ray based diagnostic apparatus, it was treated as classifiable under heading 9022 and not entitled to the claimed exemption.

Conclusion: Against the assessee.

Issue (iii): Whether IP Cassettes and Imaging Plates were classifiable under heading 9018 and eligible for exemption as accessories.

Analysis: Imaging plates and IP cassettes were treated as media used to record X-ray images and as components inserted for X-ray exposure in computed radiography. On that basis, they were held to be classifiable under heading 9018 and to satisfy the conditions for exemption under the applicable notification.

Conclusion: In favour of the assessee.

Final Conclusion: The classification and exemption denial were sustained for FCR Capsula and Dry Pix 7000, but relief was granted for IP Cassettes and Imaging Plates, resulting in only a partial modification of the appellate order.

Ratio Decidendi: Goods are to be classified according to their primary function and technical operation, and exemption follows only where the article answers the notification description on that functional basis.

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