Medical device classification must follow the principal apparatus heading where components are dedicated parts of dialysis equipment.

Imported blood filtration components were classified under the heading for parts of blood transfusion or renal dialysis apparatus because they were used solely with blood purification and dialysis equipment and were not shown to fit any specific heading in Chapter 84, 85 or 91. The court applied Note 2 to Chapter 90 and treated the goods as parts and accessories of the principal medical apparatus, rejecting the broader filtering machinery heading as less specific. It also found Circular No. 19/2013 inconsistent with the statutory classification scheme, quashed the circular, and set aside the demand proceedings based on it.

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Issues: Whether the imported blood filtration components were classifiable under Heading 9018 90 31 as parts of blood transfusion or renal dialysis apparatus, or under Heading 8421 29 00 as filtering machinery, and whether Circular No. 19/2013 was valid.

Analysis: The dispute turned on the scheme of classification under the Customs Tariff Act, 1975, particularly Note 2 to Chapter 90. The Court held that Note 2(a) does not exclude recourse to Chapter 90 where the goods are not covered by any heading in Chapter 84, 85 or 91, and that the imported items were not shown to fall within any specific heading in Chapter 84. The goods were found to be components used solely with blood purification and dialysis equipment, and therefore answered the description of parts and accessories to be classified with the principal apparatus under Note 2(b). The general heading for filtering machinery could not displace the more appropriate classification linked to the specific medical apparatus.

Conclusion: The goods were held classifiable under Heading 9018 90 31 and not under Heading 8421 29 00. Circular No. 19/2013 was held to be inconsistent with the statutory scheme and was quashed, and the demand proceedings based on it were set aside.

Final Conclusion: The writ petitions succeeded and the petitioner obtained relief against the differential duty demand on the basis of the impugned circular.

Ratio Decidendi: Where goods are specially suited as parts or accessories of a particular apparatus and no specific heading in another chapter squarely covers them, classification must follow the provision governing the principal apparatus rather than a broader general heading.

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