Electrical classification of fingerprint readers under CTH 8543 prevailed over residuary mechanical heading, applying Rule 3(c).

Touch fingerprint readers were treated as electrical machines with an individual function under CTH 8543 7099 rather than as residuary machines or mechanical appliances under CTH 8479. The analysis found that the goods operated on electrical technology and were not merely mechanical parts of another machine, making the electrical-machinery heading the better fit. It also noted that, where two headings are equally applicable, Rule 3(c) of the General Rules for Interpretation directs classification under the heading occurring last in numerical order. On that basis, the Revenue's challenge on classification succeeded and the lower authority's classification was rejected.

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Issues: Whether touch finger print readers were classifiable under CTH 8479 as machines or mechanical appliances having individual functions not specified elsewhere, or under CTH 8543 as electrical machines and apparatus having individual functions not specified or included elsewhere, and whether Rule 3(c) of the General Rules of Interpretation of Import Tariff required classification under the heading occurring last in numerical order.

Analysis: CTH 8479 is a residuary entry for machines and mechanical appliances of a mechanical nature, and the goods in question could not be treated as parts of any machine covered by that heading. By contrast, CTH 8543 covers electrical machines and apparatus having individual functions not specified elsewhere in the chapter, which better matched the nature of finger print readers operating on electrical technology. The Rule of Interpretation also supported classification under the heading that occurs last in numerical order where two headings equally merit consideration.

Conclusion: The goods were correctly classifiable under CTH 8543 7099 and not under CTH 8479.

Final Conclusion: The Revenue's challenge succeeded and the classification adopted by the lower authority was rejected in favour of the Department.

Ratio Decidendi: Where a product is an electrical device with an individual function and is not covered by a more specific heading, it falls under the electrical-machinery entry rather than a residuary mechanical-appliance heading; if two headings equally apply, classification follows the heading occurring last in numerical order under the interpretative rules.

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