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Issues: Whether the image runner multifunction network printers were classifiable as computer peripherals under Schedule I, Part B, Entry 18(i) of the Tamil Nadu General Sales Tax Act or under the residuary entry in Schedule I, Part C, Entry 13(i).
Analysis: The goods were found to work in conjunction with a computer and to function as input and output devices. Their predominant function was printing, with scanning, copying and faxing being ancillary features. The nature of the equipment and its functional utility, rather than a fragmented view of its individual capabilities, was held to be decisive. A commodity cannot be placed in a residuary entry when a specific entry covers it. On that basis, the machine was treated as a computer peripheral, and the presence of other functions did not displace that classification.
Conclusion: The image runner multifunction printers fell within Schedule I, Part B, Entry 18(i) and not the residuary classification; the classification adopted by the Tribunal was set aside.
Final Conclusion: The revisions were allowed and the classification issue was answered in favour of the assessee, with the goods held taxable under the specific peripheral entry.
Ratio Decidendi: Where a product's principal and predominant function brings it within a specific tariff entry, it must be classified under that entry rather than a residuary one, even if it has ancillary multifunction features.