Specific tariff classification for data projectors prevails where technical features show principal use with automatic data processing systems.

Imported data projectors are treated as classifiable under Heading 8528.61/85286100 when their technical and functional characteristics show they are of a kind solely or principally used with an automatic data processing system. Common parlance, functional utility and principal use remain relevant in tariff interpretation, and a specific tariff entry prevails over any residuary classification. Features such as native aspect ratio, resolution and contrast ratio may support ADP use. On that basis, the projectors were held eligible for exemption under Notification No. 24/2005-Cus, and the earlier coordinate bench view in the same matter was followed in the interest of judicial discipline.

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Issues: Whether the imported data projectors were classifiable under Heading 8528.61/85286100 as projectors of a kind solely or principally used in an automatic data processing system, and consequently eligible for exemption under Notification No. 24/2005-Cus dated 01.03.2005.

Analysis: The classification turned on the proper approach to tariff interpretation. The accepted principles applied were that there is no single fixed test for classification, that common parlance remains relevant, but that functional utility and principal use also matter where the tariff entry is based on sole or principal use. A specific tariff entry must prevail over a residuary entry. The technical features of the projectors, including native aspect ratio, resolution and contrast ratio, were treated as relevant indicators of their intended use with computers and other ADP systems. The earlier coordinate bench decision in the appellant's own case, which had already classified similar projectors under Heading 8528.61, was followed in the interest of judicial discipline.

Conclusion: The goods were held classifiable under Heading 85286100 and entitled to the benefit of Notification No. 24/2005-Cus.

Ratio Decidendi: Where projectors are shown, on their technical and functional characteristics, to be of a kind solely or principally used with an automatic data processing system, they fall under the specific heading for such projectors and cannot be shifted to a residuary classification merely because they also possess video compatibility.

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