CESTAT Chennai Grants MRI Accessory Exemption to Philips India

Date: 28.07.2025

The Customs, Excise, and Service Tax Appellate Tribunal (CESTAT), South Zonal Bench, Chennai, recently delivered a significant judgment in the case of M/s Philips India Limited vs. ​ The Commissioner of Customs (Air Cargo). ​ This case revolved around the classification and eligibility for customs duty exemptions of the Sonalleve MR HIFU KIT, a specialized medical device used in conjunction with MRI machines. ​ The ruling not only clarified the classification of the product but also reinforced the importance of adhering to the scope of Show Cause Notices in customs proceedings.

M/s Philips India Limited had imported the Sonalleve MR HIFU KIT, declaring it as an accessory to MRI machines under Customs Tariff Heading (CTH) 9018 13 00. ​ The company claimed concessional rates of Basic Customs Duty (BCD) and Countervailing Duty (CVD) under Notification No. ​ 21/2002-Cus and Notification No. ​ 6/2006-CE, respectively. ​ However, the customs department issued a Show Cause Notice alleging that the imported goods were not accessories to MRI machines and denied the claimed exemptions. ​ The original authority upheld this view, leading to the confirmation of differential duty along with interest.

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