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of <h1>Imported Memory Array Boards classified as computer accessories under specific heading, not separately housed units. Upheld decision.</h1> <h3>TELCO Versus COLLECTOR OF CUSTOMS., MUMBAI</h3> TELCO Versus COLLECTOR OF CUSTOMS., MUMBAI - 1997 (94) E.L.T. 549 (Tribunal) Issues: Classification of imported goods under Heading 8471.93 or 8473.30In this case, the issue at hand is the classification of imported Memory Array Boards for a computer system under either Heading 8471.93 or 8473.30. The appellant claimed clearance under Heading 8471.93, but the Assistant Collector rejected the claim, classifying the goods as computer accessories under Heading 8473.30. The Collector (Appeals) upheld this classification, leading to the appeal.Analysis:The Tribunal considered the relevant Note 5B to Chapter 84, which outlines the conditions for a unit to be classified under 84.71. The Note specifies that a unit must be connectable to the Central processing unit, designed as part of the system, and separately housed to be classified under 84.71. The lower appellate authority detailed why the goods in question should be classified under 84.73 as accessories rather than under 84.71. The authority noted that the Memory Array Boards enhance the capacity of the existing system, contributing to an increase in its range of operations, making them appropriate for classification as accessories under Heading 84.73. The goods were designed for mounting on the Memory Controller, satisfying the conditions for classification as an accessory under 84.73.The Tribunal emphasized that since the imported goods were not contained in separately housed units, they did not meet the requirements for classification under Heading 84.71. Therefore, the Tribunal upheld the lower appellate authority's decision to classify the goods as accessories under Heading 84.73 and rejected the appeal. The judgment highlights the importance of meeting specific conditions for classification under different headings within the Customs Tariff Act to determine the appropriate classification of imported goods accurately.
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