Imported Medical Thermal Printers For Diagnostic Use Classifiable As ‘Medical Instruments’: CESTAT

The Delhi Bench of the Customs, Excise & Service Tax Appellate Tribunal (CESTAT) held that thermal printers imported for medical diagnostic purposes are classifiable as medical instruments under Chapter 90 of the Customs Tariff and not as ordinary printers under Chapter 84. The Bench of Justice Dilip Gupta (President) and Hemambika R. Priya (Member Technical) has distinguished the imported printers from general-purpose thermal printers used in retail, logistics or industrial applications. While thermal printing technology may be common, the medical-grade printers under consideration were specially designed for diagnostic imaging and met stringent quality standards necessary for accurate medical evaluation. The dispute arose from the classification of “Drystar” thermal printers imported by AGFA between July 1, 2017 and March 31, 2019. The company had classified the goods under Customs Tariff Item (CTI) 9018 90 99, covering instruments and appliances used in medical, surgical, dental or veterinary sciences. On this basis, it paid Basic Customs Duty at 7.5% (after claiming exemption under Notification No. 50/2017-Cus) and IGST at 12%. However, the Directorate of Revenue Intelligence took the view that the printers were classifiable under CTI 8443 32 90, which covers other printers capable of connecting to an automatic data processing machine or network. According to the department, the printers did not perform any diagnostic function and merely printed images generated by CT and MRI machines. Consequently, a show cause notice was issued proposing reclassification, recovery of differential duty under Section 28(4) of the Customs Act, confiscation of goods, and imposition of penalties on both the company and its Manager, Customer Operations, Mr. Yogesh More. The Additional Director General (Adjudication) confirmed the demand, holding that the printers were standard network printers capable of connecting to ADP systems and that diagnosis could be carried out by viewing images on monitors without requiring printed films. It was further alleged that the importer had misdeclared the classification under the self-assessment regime, justifying invocation of the extended limitation period and imposition of penalties. Challenging the order, AGFA contended that the printers were specially designed for medical diagnostic use and were capable of printing high-resolution diagnostic-quality images on heat-sensitive medical film. The company relied on product brochures, a white paper on diagnostic printing, and certificates from specialist radiologists and a Chartered Engineer to demonstrate that parameters such as spatial resolution and contrast resolution were critical for primary diagnosis and that such quality could not be achieved through ordinary desktop printers. After examining the rival submissions, the Tribunal observed that Chapter 90 covers instruments specifically designed or clearly identifiable for medical use. It noted that the decisive test is not whether the equipment performs diagnosis independently, but whether it is specially adapted and essential for professional medical practice. The Bench found that the Drystar printers were used with MRI, CT scan, digital X-ray and ultrasound systems and were capable of producing diagnostic-quality grayscale images required for radiological interpretation. The Tribunal reiterated that the burden to prove reclassification lies on the department. Relying on settled legal principles, it held that if the Revenue seeks to alter the declared classification, it must produce sufficient evidence. In the present case, the department failed to rebut the technical and expert evidence produced by the appellant. Holding that the goods were correctly classifiable under CTI 9018 90 99, the Tribunal set aside the demand of differential duty, interest and penalties. Consequently, the penalties imposed on AGFA under Sections 112 and 114AA of the Customs Act were quashed. The separate penalty of Rs 10 lakh imposed on Mr. Yogesh More under Section 112(a) was also set aside. The Tribunal allowed both appeals and annulled the order dated February 17, 2020, passed by the adjudicating authority, granting complete relief to the appellants. Case Details Case Title: M/s. AGFA Healthcare India Pvt. Ltd. Versus The Additional Director General (Adjudication) Citation: JURISHOUR-42-CESTAT-2026(Del) Case No.: Customs Appeal No. 50795 of 2020 Date: 20.02.2026 Counsel For Petitioner: B.L. Narasimhan Counsel For Respondent: Mihir Ranjan Click Here To Read Order Read More: Can GST Dept. Repeatedly Summon Company Director Despite Cooperation? Gauhati HC Examines Scope of S. 70 Powers

Imported Medical Thermal Printers For Diagnostic Use Classifiable As ‘Medical Instruments’: CESTAT

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