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Issues: Whether imported operation theatre lights are classifiable under Customs Tariff Heading 9018 (in particular CTH 9018 9099) as instruments and appliances used in medical or surgical sciences, or under Heading 9405 as general lamps and lighting fittings.
Analysis: The issue was examined with reference to the First Schedule of the Customs Tariff Act, 1975 and the Explanatory Notes to Heading 9018 and Chapter 90, including Note 1(ij) to Chapter 90 which excludes searchlights and spotlights of heading 9405. The technical specifications and catalogue for the subject goods show features characteristic of specialised medical apparatus: adjustable colour temperature, facetted multi-lens systems to minimise shadowing, high colour rendering indices, illumination-in-depth control, sterilizable handles, optional integrated video systems, and design features promoting laminar flow and hygiene. The goods are identified in a DGHS notice as operation theatre devices and are not ordinary general-purpose lamps. Prior tribunal and appellate authority decisions on materially similar operation theatre lights holding classification under heading 9018 were considered, together with authorities on the relevance of function and end-use and the principle of judicial discipline requiring subordinate authorities to follow binding appellate conclusions unless stayed. The catalogue and technical characteristics were held to make the goods clearly identifiable as for medical/surgical use and not mere lighting fittings covered by heading 9405.
Conclusion: Operation theatre lights are specialised instruments and appliances used in medical or surgical sciences and are classifiable under Customs Tariff Heading 9018, specifically under the residuary subheading 9018 9099.