CESTAT Delhi- Thermal Printers Classified as Medical Equipment Under CTI 9018

ALO Law Office- IDT Tax I Arbitration I Litigation

Date: 21.02.2026

CESTAT Delhi- Thermal Printers Classified as Medical Equipment Under CTI 9018

In a significant ruling, the Customs, Excise & Service Tax Appellate Tribunal (CESTAT), Principal Bench, New Delhi, delivered a judgment on February 20, 2026, addressing the classification of thermal printers imported by M/s AGFA Healthcare India Pvt. Ltd. The case revolved around whether these printers should be classified under Customs Tariff Item (CTI) 9018 90 99, as medical diagnostic equipment, or under CTI 8443 32 90, as general printing machinery. ​

Background of the Case

M/s AGFA Healthcare India Pvt. ​ Ltd., a company engaged in trading and distributing medical equipment, imported various models of thermal printers, including Drystar 5301, Drystar 5302, Drystar 5503, and Drystar Axys, between July 1, 2017, and March 31, 2019. ​ These printers were used to produce high-quality medical films for diagnostic purposes in hospitals, medical laboratories, and colleges. ​ The company classified these printers under CTI 9018 90 99, which covers instruments and appliances used in medical sciences, and availed exemptions under Notification No. ​ 50/2017-Customs.

However, the Directorate of Revenue Intelligence (DRI) initiated investigations and argued that the printers should be classified under CTI 8443 32 90, which pertains to general printing machinery. ​ The DRI contended that the printers did not perform diagnostic functions and were capable of connecting to Automatic Data Processing (ADP) machines or networks, making them general-purpose printers. Consequently, the DRI issued a show-cause notice proposing reclassification and demanded differential duty, interest, and penalties under various sections of the Customs Act, 1962. ​

Key Issues in the Case

The primary issue before the Tribunal was the classification of the imported thermal printers. ​ The department argued that the printers were general-purpose printing machinery, while the appellant contended that they were specifically designed for medical diagnostic purposes and should be classified under CTI 9018 90 99. ​

Arguments Presented

Appellant’s Arguments:

1. Burden of Proof: The appellant argued that the burden of proving reclassification lies with the department, which failed to provide sufficient evidence. ​
2. Medical Use: The thermal printers were specifically designed for medical sciences, capable of producing diagnostic-quality images on heat-sensitive medical films. ​ These printers were integral to the diagnostic process. ​
3. Technical Evidence: The appellant presented technical literature, product brochures, and expert declarations from medical professionals and engineers to substantiate their claim that the printers were medical diagnostic equipment.
4. Legal Precedents: The appellant cited previous judgments where goods specifically designed for medical use were classified under Chapter 90, even if they shared general characteristics with items in other chapters. ​

Department’s Arguments:

1. General Printing Machinery: The department argued that the printers were not exclusively used for medical diagnostics and could connect to ADP machines or networks, making them general-purpose printers. ​
2. Extended Limitation Period: The department justified invoking the extended period of limitation under Section 28(4) of the Customs Act, citing misdeclaration and suppression of facts by the appellant. ​
3. Penalties and Interest: The department defended the imposition of penalties and interest, asserting that the appellant intentionally misclassified the goods to evade higher customs duties.

Tribunal’s Observations and Decision ​

After considering the arguments and evidence, the Tribunal ruled in favor of M/s AGFA Healthcare India Pvt. Ltd. The key observations and conclusions were:

1. Classification Under CTI 9018: The Tribunal held that the thermal printers imported by the appellant were specifically designed for medical diagnostic purposes. ​ They were capable of producing diagnostic-quality images on medical films, which are essential for accurate diagnosis in radiology. ​ The printers were deemed medical equipment and classified under CTI 9018 90 99. ​
2. Burden of Proof: The Tribunal emphasized that the burden of proving reclassification lies with the department. ​ In this case, the department failed to provide evidence that the printers were not used for medical diagnostics, while the appellant presented substantial technical and expert evidence supporting their claim. ​
3. Legal Precedents: The Tribunal referred to previous judgments, including Westfort Hi-Tech Hospital Ltd. vs. Commissioner of Customs, Cochin and Prosoya Industries Ltd. vs. Collector of Customs, New Delhi, which established that goods specifically designed for medical use should be classified under Chapter 90. ​
4. Extended Limitation Period: The Tribunal found that the department’s invocation of the extended period of limitation under Section 28(4) of the Customs Act was not justified, as the appellant had not engaged in suppression of facts or misdeclaration.
5. Penalties and Interest: Since the demand for differential duty was set aside, the penalties and interest imposed on the appellant and its manager, were also quashed. ​

Implications of the Judgment ​

This landmark decision has significant implications for the classification of goods under the Customs Tariff Act. ​ It reinforces the principle that goods specifically designed for medical use should be classified under Chapter 90, even if they share general characteristics with items in other chapters. ​ The ruling also underscores the importance of technical evidence and expert opinions in determining the classification of goods. ​

For businesses importing medical equipment, this judgment serves as a reminder to maintain detailed documentation and technical specifications to substantiate their claims during customs assessments. ​ It also highlights the need for the department to provide concrete evidence when challenging the classification of goods. ​

Conclusion

The CESTAT’s decision in favor of M/s AGFA Healthcare India Pvt. Ltd. is a victory for businesses importing specialized medical equipment. It sets a precedent for the classification of goods under the Customs Tariff Act and provides clarity on the importance of technical evidence in such cases. This ruling is a testament to the importance of a fair and thorough examination of facts and evidence in resolving disputes related to customs classification.

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Source: CESTAT Delhi

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