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Issues: (i) Whether thermal printer ribbons proposed to be imported are classifiable under Tariff Item 8443 99 59 of the First Schedule to the Customs Tariff Act, 1975 instead of Chapter Heading 9612; (ii) What rate of duty applies to thermal printer ribbons classified under Tariff Item 8443 99 59.
Issue (i): Whether thermal printer ribbons proposed to be imported are classifiable under Tariff Item 8443 99 59 of the First Schedule to the Customs Tariff Act, 1975 instead of Chapter Heading 9612.
Analysis: The product was found to be specially designed for use only with thermal ID card printers and to operate as an integral component of the printing process. Applying Section Note 2 of Section XVI, parts suitable solely or principally for use with a particular machine are to be classified with that machine, unless excluded by a specific provision. The product was also found not to answer the description of typewriter or similar ribbons under Chapter 9612, because its function is heat-based thermal transfer printing and not impression printing by impact, and its physical characteristics differ from ordinary typewriter ribbons. On that basis, the product was treated as falling within the residual parts and accessories entry for goods of sub-heading 8443 32.
Conclusion: The classification under Tariff Item 8443 99 59 was upheld and Chapter Heading 9612 was rejected.
Issue (ii): What rate of duty applies to thermal printer ribbons classified under Tariff Item 8443 99 59.
Analysis: Once the product was classified under Tariff Item 8443 99 59, the applicable duty consequence was determined on that classification basis.
Conclusion: The applicable duty was held to be BCD nil and IGST 18%.
Final Conclusion: The product was conclusively treated as a part or accessory of thermal printers under the specified customs tariff entry, and the corresponding duty liability was determined accordingly.
Ratio Decidendi: A product specially designed for sole or principal use with a particular machine is classifiable as a part or accessory of that machine, and a heat-transfer ribbon used in thermal printing is not a typewriter or similar ribbon prepared for impression by impact.