Tariff classification of a CPU board turned on its data-processing function, placing it under Chapter 84 rather than Chapter 90.

An imported CPU board for an atomic absorption spectrophotometer was treated as a distinct data-processing unit because it performed signal processing and converted received data into digital words for computation. Applying Chapter Note 2(a), the classification under Chapter 90 and Heading 98.06 was rejected because the item was not itself a Chapter 90 part and fell within the specific tariff entry in Chapter 84 for automatic data-processing machines and units thereof. The customs classification under sub-heading 8473.30 and the countervailing duty classification under sub-heading 8473.00 were therefore upheld against the assessee.

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Issues: Whether the imported CPU Board for an atomic absorption spectrophotometer was classifiable under Chapter Sub-heading 9027.90 read with Heading 98.06 of the Customs Tariff Act, 1975, or under Chapter Sub-heading 8473.30 of the Customs Tariff Act, 1975 and for CVD under Chapter Sub-heading 8473.00 of the Central Excise Tariff Act, 1985.

Analysis: The imported item was found to be a CPU Board performing signal processing and converting the received data into digital words for computation, thereby functioning as a data processor. For classification under Chapter 90, the relevant Chapter Note 2(a) required examination whether the goods were themselves goods included in Chapter 90 or, alternatively, goods classifiable in Chapters 84, 85 or 91. The CPU Board was not identified as a part specifically falling under Chapter 90, but was held to be a distinct unit covered by Chapter 84, which contains a specific entry for automatic data processing machines and units thereof. On that basis, the claimed classification under Chapter 90 and Heading 98.06 was rejected.

Conclusion: The imported CPU Board was correctly classified under Chapter Sub-heading 8473.30 for customs duty and under Chapter Sub-heading 8473.00 for countervailing duty, against the assessee.

Final Conclusion: The classification adopted by the lower authorities was upheld and the appeal failed.

Ratio Decidendi: Where an imported component performs a distinct data-processing function and falls within a specific tariff entry in Chapter 84, it is to be classified under that specific entry rather than as a part of a Chapter 90 instrument.

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