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Issues: Whether the imported fingerprint reader was classifiable under heading 8471 as a part or accessory of automatic data processing machines, or under heading 8543 as an electrical machine having an individual function.
Analysis: The product was found to function as a fingerprint reader/biometric device and not as a document scanner or as a part or accessory of a computer. Applying the tariff scheme and Chapter Note 5(E) to Chapter 84, machines performing a specific function other than data processing and those working in conjunction with an automatic data processing machine are to be classified according to their respective functions or in the residual heading. The device's specific function was to identify the user and transmit data for further processing, which placed it outside heading 8471. The earlier Tribunal view on similar fingerprint readers and attendance-related data collection devices was followed, and the specific classification under heading 8543 was preferred over the claimed heading 8471.
Conclusion: The imported product was correctly classifiable under heading 8543 and not under heading 8471, and the Revenue's appeal succeeded.
Ratio Decidendi: A device with an independent specific function that is not itself a data-processing machine or a true part or accessory of one must be classified under the heading appropriate to that function, and if necessary under the residual tariff heading rather than under heading 8471.