Madras High Court
M/S.Unitech Enterprises vs The Customs on 17 February, 2021
Bench: T.S.Sivagnanam, R.N.Manjula
CMA.No.4719 of 2019
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED : 17.02.2021
CORAM
THE HONOURABLE MR.JUSTICE T.S.SIVAGNANAM
and
THE HONOURABLE MS.JUSTICE R.N.MANJULA
Judgment Reserved On Judgment Pronounced On
27.01.2021 17.02.2021
Civil Miscellaneous Appeal No.4719 of 2019
and C.M.P.No.26818 of 2019
M/s.Unitech Enterprises,
88, Rana Pratap Market,
Karol Bagh, New Delhi – 110 005. ...Appellant
Vs
1.The Customs, Excise & Service Tax
Appellate Tribunal, South Zonal Bench,
Shasthri Bhawan Annexe, 1st Floor,
26, Haddows Road, Chennai - 600 006.
2.The Commissioner of Customs (Imports),
Customs House, No.60, Rajaji Salai,
Chennai – 600 001. ...Respondents
Civil Miscellaneous Appeal filed under Section 130(1) of the Customs
Act, 1962 against the impugned order of the Hon'ble Tribunal in Final Order
No.153/2012 dated 02.03.2012 in Appeal No.C/288/09 on the file of the
Customs, Excise & Service Tax Appellate Tribunal, Chennai.
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https://www.mhc.tn.gov.in/judis/
CMA.No.4719 of 2019
For Appellant : Mr.N.Viswanathan
For Respondents : Mr.M.Santhanaraman
Senior Standing Counsel
JUDGMENT
(Delivered by T.S.Sivagnanam,J) This appeal filed by the appellant under Section 130(1) of the Customs Act, 1962 ['the Act' for brevity] is directed against the order dated 02.03.2012 made in Final Order No.153/2012 passed by the Customs, Excise & Service Tax Appellate Tribunal, Chennai ['the Tribunal' for brevity].
2.This civil miscellaneous appeal has been filed by raising following substantial questions of law:
“1.Whether order of the Tribunal could be sustained in the light of the judgment of this Hon'ble Court vide its order dated 27.02.2012?
2.Whether the Tribunal has the power and jurisdiction to hold the decision of the co-ordinate bench to be erroneous, being contrary to the judgment of the Hon'ble Supreme Court of India?
3.Whether the Tribunal was right in interpreting the meaning of the term “photocopier machines” 2/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 appearing in para 2.17 of the Foreign Trade Policy based on common parlance by assuming the intention of the Government to cover photocopies in general without properly considering the ration of the judgment of the Hon'ble Supreme Court of India in the Akbar Badruddin Jiwani case?”
3.The appellant, a proprietary concern is engaged in the business of import and trading of digital multifunction print and copying machines having its office at New Delhi. They had filed bill of entry dated 13.08.2009 for clearance of “Old/Used Analogue Photocopiers and Old/Used Digital Multi functional (Print and Copying) Machines”of various models at a declared value of USD59870 [C&F] from a supplier based in United States of America. The Department found the goods to be second hand goods not consigned from any manufacturer or from the user of the goods, but were procured from a distributor/dealer who deals with such goods. The Department referred to a circular issued by the Central Board of Excise and Customs [CBEC] in Circular No.4/2008-Customs dated 12.02.2008 regarding the valuation of second hand machines. In terms of the said circular, the goods are required to be accompanied by a certificate 3/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 issued by a Chartered Engineer or any equivalent in the Country of supply. The certificate was required to indicate, (i) Price of New machinery as in the year of its manufacture; (ii) Current CIF value of new machinery if purchased new; (iii) Year of the manufacture of machinery; (iv) Sale Price of the supplier; (v) Present condition of machinery; (vi) Nature of reconditioning or repairs carried our, if any, and the cost thereof and (vii) Expected life span.
4.It is not in dispute that the imported second hand goods was not accompanied by such a certificate. This resulted in the goods being examined for verifying the declaration regarding the goods and also to appraise the value of the goods by an approved Chartered Engineer. The same was accordingly done and the Chartered Engineer by report dated 21.08.2009 certified the goods as “Old/Used Analogue Photocopiers and Old/Used Digital Multi functional (Print and Copying) Machines” and stated that they are from 4 to 10 years old, the machines are used and not reconditioned and the value of the second hand goods was appraised as USD 69395 [C&F].
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5.The Department placed reliance on paragraph 2.17 of the Foreign Trade Police [hereinafter referred to as “FTP”] which states that all second hand goods, except second hand capital goods, shall be restricted for import and may be imported only in accordance with provisions of FTP, ITC(HS), HBP. Para 2.17 of FTP further states that import of second hand capital goods, including refurbished/reconditioned spares shall be allowed freely. However, second hand personal computers/laptops, photocopier machines, air conditioners, diesel generating sets will only be allowed against a license. Import of re-manufactured goods shall be allowed against a license. As the appellant did not produce the license for import of the said machines, the Department proposed to confiscate the goods under Section 111(d) of the Act r/w. Section 3(3) of the Foreign Trade (Development and Regulation) Act, 1992 [hereinafter referred to as “the FTDR Act”]. As the goods were not accompanied by a Chartered Engineer's certificate as mentioned in CBEC circular No.4/2008-Customs, the Department opined that the value of the goods have to re-determined under Rule 9 of the Customs Valuation [Determination of Price of Imported Goods] Rules, 2007 [hereinafter referred to as “CVR”]. The Chartered Engineer appraised the value of the goods at USD 69395 [C&F].
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6.The appellant vide letter dated 21.08.2009 stated that the price and value offered by their supplier and the actual transaction price were true, however, agreed to accept USD 69395 [C&F] as assessed by the Chartered Engineer. The appellant further stated that the DGFT authorities vide notification No.31/2005 dated 19.10.2005 have restricted second hand photocopier machines which was originally falling under Customs Tariff Heading [CTH] No.90091200 which shall later included in Customs Tariff Heading No.84433930 in December 2006; imported goods falling under Customs Tariff Heading No.84433100 and cannot be considered as photocopier machines nor parts of computer as the predominant feature of the machine is printing with ancillary function of copying but not photocopying. The appellant explained the usage of the said machinery and contended that the same should be allowed under “free” category in terms of para 2.17 of Exim Policy as second hand capital goods [second hand printing machines]. So far as 36 units of second hand photocopier machines falling under CTH No.90091200 and at the relevant time falling under CTH No.84433930 being restricted as per the Exim Policy, may be adjudicated by taking a lenient view as they have not applied for import license for the reason that the value of the goods are insignificant.
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7.The appellant requested adjudication of case without issuance of show cause notice and personal hearing. The adjudicating authority, namely, the Commissioner of Customs [Seaport-Import], Chennai framed two issues for consideration, namely, (i) the licensing aspect of the imported goods and (ii) its valuation. The goods consisted of 201+36 units. The appellant admitted that 36 units were old/used Analogue Photocopiers and accepted that import of these used Photocopiers requires a license which the appellant did not possess and therefore requested that their case may be adjudicated. Thus, the dispute was in respect of 201 units which the appellant claimed to be not Photocopiers but Digital Multi Function Machines which was freely importable as it would fall within the ambit of second hand capital goods and in terms of para 2.17 of the FTP freely importable. The correctness of this stand was considered by the adjudicating authority after taking note of the submissions made by the appellant. It was held that as per the unamended Foreign Trade Policy 2004-2009, in terms of para 2.17 therein, all second hand capital goods are restricted for import. Further, the adjudicating authority observed that notification No.31/2005 dated 19.10.2005 issued by the DGFT merely introduced an amendment to para 2.17 of the FTP though stated that import 7/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 of second hand capital goods including refurbished/reconditioned spares shall be allowed freely, second hand personal computers/laptops, photocopiers, air conditioners and diesel generating sets will be allowed against license. Further the adjudicating authority observed that Digital Multi Function Machine performs the function of photocopying as well as printing and it would be the same as that of a photocopying machine with additional facility of printing when connected with a machine and in terms of amended para 2.17, photocopiers as well as personal computers including laptops are restricted items. Therefore, the adjudicating authority held that import of such items require a license which the appellant did not possess and therefore, the goods are liable for confiscation under section 111(d) of the Act.
8.The next issue, namely, valuation was taken up for consideration by the adjudicating authority and proceeded to determine the value of the goods. Thus, the adjudication having been completed the order-in-original dated 26.08.2009 was passed rejecting the value declared by the appellant and re-determining the same at USD 69395 [C&F] equivalent to Rs.34,15,893/-[AV] under Rule 9 of CVR 2007; confiscate the goods under 8/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 section 111(d) of the Act r/w. Section 3(3) of the FTDR with an option to redeem the same on payment of find of Rs.10,25,000/- under Section 125 of the Act subject to payment of applicable rate of duty; penalty of Rs.13,70,000/- was imposed on the appellant under section 112(a) of the Act.
9.The appellant challenged the said order before the Tribunal. After considering the submissions made by the appellant, the Tribunal framed three issues for consideration, namely, i. Whether the impugned goods which were declared as “old and used digital multifunction print and copying machines” can be considered to be a photocopiers and import of which requires a license?
ii. Whether the fine and penalty imposed are excessive? iii. Whether the value determined by the Customs authorities for the impugned goods is proper or arbitrary?
10.So far as the valuation aspect is concerned, no question of law has been framed for consideration. Therefore, we need to take note of the finding rendered by the Tribunal on the question as to whether the goods 9/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 which were imported by the appellant can be considered to be photocopiers, import of which requires a license in terms of para 2.17 of the FTP. After taking note of various decisions rendered by the Tribunal and the decision of the Hon'ble Supreme Court in Xerox India Ltd. vs. Commissioner of Customs, Mumbai [2010 (260) ELT 161(SC)], the Tribunal held that the imported goods fall under CTH 84433100 and on facts held that the decision in Xerox India Ltd., cannot be made applicable to the appellant's case as in the said decision there was a classification dispute which is not the case in so far as the appellant's import is concerned. Further, the Tribunal referred to the decision in the case of Atul Commodities Pvt. Ltd. vs. Commissioner of Customs, Cochin [2009 (235) ELT 385 (SC)], wherein it was held that import of photocopying machines stand restricted on or after 19.10.2005 and neither in the amending notification No.31/2005 dated 19.10.2005 nor in the judgment in Atul Commodities Pvt. Ltd. there is any reference to the import restriction being limited to photocopying machines falling under particular tariff item. Further, the Tribunal observed that the language of the amending notification clearly says that import of capital goods shall be allowed freely, however, second hand personal computers/laptops, photocopier machines, etc. will only be allowed against 10/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 the license issued in this behalf. Therefore, the Tribunal held that the restriction is not with reference to any particular tariff item.
11.Further, the Tribunal noted that photocopying machines are classified under various headings such as electrostatic photocopying apparatus-CTH 84433920, another apparatus falling under CTH 84433930, another apparatus with optical system falling under CTH 84433940 and another apparatus falling under CTH 84433950. Thus, the Tribunal concluded that photocopying machines do not have any single entry in Tariff and copying machines whether or not combined with printers and facsimile machines are classified elsewhere as also machines which perform two or more functions of printing, copying or facsimile transmission as in the appellant's case. Further, the Tribunal noted that Notification No.31/2005 was issued in the public interest and was intended to cover all kinds of photocopiers irrespective of its classification. The Tribunal dealt with the arguments of the appellant that the imported machine is different from analog photocopiers but rejected the said contention on the ground that the notification dated 19.10.2005 does not carve out any such distinction. 11/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019
12.In Paragraph 14 of the impugned order, the Tribunal has drawn a comparison between analog photocopier machine and the digital photocopier machine which was imported by the appellant and on facts held that the multifunction printing and copying machines are also essentially digital photocopiers which can be connected to an automatic data processing machine and thus, the printing function of the machine sub serves and is essential to produce a photocopy. The Tribunal observed that they took judicial notice of the fact that the imported items are known as photocopier machines found almost in every street in cities which are popularly known as “Xerox machines”. The Tribunal referred to the Government of India's Directorate General of Supplies and Disposals [DGS&D] rate contract list which classifies multifunction machines under the list of photocopier machines and the South Zonal Bench of the Tribunal had made a proposal for purchase of such machine and when quotations are received and purchase was made for photocopier machines, what was supplied is machines similar to the imported goods. Further, the Tribunal referred to the stand taken by the DGFT in an appeal filed before the Division Bench of this Court in Writ Appeal No.1802/2011 stating that second hand multipurpose photocopier is also restricted like a photocopier 12/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 machine. Thus, by an elaborate order the Tribunal dismissed the appeal filed by the appellant and the only relief the appellant got before the Tribunal was a reduction in the penalty from Rs.13,70,000/- to Rs.6,85,000/-. Aggrieved by the impugned order, the appellant has filed the present appeal.
13.Mr.N.Viswanathan, learned counsel appearing for the appellant placed reliance on the decision of the learned Single Bench of this Court in the case of Anand Impex vs. Commissioner of Customs [Seaport-Import], Chennai [2012 (281) ELT 178 (Madras)] and submitted that in the said decision, it was held that digital multifunction print and copying machine is not restricted for import and therefore, the order passed by the Tribunal is liable to be set aside. Further, it is submitted that the Tribunal erred in not following the decision of the co-ordinate Bench of the Tribunal which they are bound to follow or if they do not agree with the reasoning, the matter should have been referred to the Larger Bench for consideration and not following a decision of the co-ordinate Bench would amount to judicial indiscipline. Further, it is submitted that even after December 2006 when the impugned goods were brought under a specific heading-CTH 8443 31 13/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 unlike photocopiers which was classified under the sub heading 8443.39, the Tribunal ought to have held that the impugned goods do not attract the restriction in terms of para 2.17 of the FTP.
14.The other grounds which were raised before the Tribunal were reiterated by the learned counsel. Reliance was placed on the decision in the case of Gammon India Ltd. vs. Commissioner of Customs, Mumbai [2011 (269) ELT 289 (SC)] and the decision of the Bangalore Tribunal in the case of Shivam International vs. Commissioner of Customs, Cochin [2012 (286) ELT 545 (Tri-Bang) to support the argument that the Tribunal ought to have followed the decision of the co-ordinate Bench of the Tribunal and in not doing so, it has created a judicial uncertainty. Further the learned counsel commented upon the finding of the adjudicating authority, more particularly, in paragraph 7 of the order-in-original dated 26.08.2009 and submitted that the finding of the authority was erroneous. Placing reliance on the decision in the case of Akbar Badruddin Jiwani vs. Collector of Customs [1990 (47) ELT 161(SC)], it is submitted that in the taxing statute words used are to be understood in common parlance or commercial parlance, especially when the Tariff Entry has not been used in 14/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 a scientific or technical sense. For the same proposition, reliance was placed on the decision of the West Regional Bench, Bombay in the case of Collector of Customs, Bombay vs. Hargovindas & Co. [1987 (29) ELT 975(Tribunal)]. On the above grounds, the learned counsel prayed for allowing the appeal and answering the substantial questions of law in favour of the appellant.
15.Mr.M.Santhanaraman, learned senior standing counsel appearing for the respondents sought to sustain the impugned order and submitted that a thorough examination of facts had been done by the adjudicating authority, the said finding was considered for its correctness by the Tribunal and after re-examining the entire facts and also noting the legal position, the appeal was dismissed and there is no substantial question of law arising for consideration in this appeal warranting interference with the impugned order.
16.We have elaborately heard the learned counsels for the parties and carefully perused the materials placed on record.
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17.As mentioned above, the only question to be considered is whether the finding rendered by the Tribunal holding that what was imported by the appellant was a restricted item was correct and whether the reasons assigned by the Tribunal to confirm the order of the adjudicating authority calls for any interference. Firstly, we need to note that the matter relates to a classification dispute and if that is so, the present appeal itself would be not maintainable before this Hon'ble Court. Nevertheless, such objection was not raised by the revenue before us. Therefore, we proceed to examine as whether the interpretation given by the adjudicating authority to justify his conclusion that the machineries which were imported are restricted items is just and proper.
18.The appellant had imported 36 units of Old/Used Analogue Photocopiers without obtaining a license. Having accepted the stand taken by the Department, the appellant requested that his case may be adjudicated. Therefore, the dispute was only with regard to 201 units of Old/Used Digital Multi functional (Print and Copying) Machines. The import was effected by filing of Bill of Entry dated 13.08.2009. The Department was of the prima facie view that the item imported is a restricted item in terms of para 2.17 of 16/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 the FTP which allows import of second hand capital goods including refurbished/reconditioned spares without obtaining a license. There are two limbs to para 2.17 of the FTP and for easy reference, we quote the same hereunder:
Para 2.17 of the Foreign Trade Policy “All second hand goods, except second hand capital goods, shall be restricted for imports and may be imported only in accordance with provisions of FTP, ITC(HS), HBP vl. Public Notice or an Authorisation issue in this regard.
Import of second hand capital goods, including refurbished/re-conditioned spares shall be allowed freely. However, second hand personal computers/laptops, photocopier machines, air conditioners, diesel generating sets will only be allowed against a license.
Import of re-manufactured goods shall be allowed against a license.”
19.In terms of the above, all second hand goods except second hand capital goods are restricted for import. It is not in dispute that 201 machines which were imported by the appellant were second hand goods. Thus, going by the first limb of para 2.17, license is required. In the second para, the Policy allows import of second hand capital goods including 17/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 refurbished/reconditioned spares without obtaining any license. There is a restriction for import of second hand Photocopier machines and other items mentioned therein. The appellant did not produce a Chartered Engineer's certificate when the goods were imported. Therefore, the goods were subjected to examination by Docks Officer in the presence of a Chartered Engineer and certified that the goods are 4 to 10 years old, they are used and not reconditioned and the value of the second hand goods was appraised as USD 69395 [C&F]. The appellant's argument before the adjudicating authority is that the imported item is totally different and it can neither be considered as a photocopier machine nor part of computer and therefore, freely importable. The adjudicating authority took note of the unamended FTP and also the position after the amendment by notification dated 19.10.2005 and on facts, found that the digital multifunction machine imported by the appellant performs the function of photocopying as well as printing. It further held that the function is same as of the photocopying machine with additional facility of printing when connected to a computer. The correctness of this finding was re-examined by the Tribunal and in our considered view very elaborately. It analysed various uses of the machine and drew a comparative chart which is as follows:
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https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 Analog Photocopier Machine Digital Photocopier Machine
1. The original document is scanned to 1. The original document is scanned to create an optical image create an optical image
2. The image is directly projected on to 2. The optical image is converted to the photoreceptor digital data which is sent to the printer engine to create the printed image on to the photoreceptor
3. The image is developed on the 3. The image is developed on the photoreceptor and copied on the paper. photoreceptor and copied on the paper.
20.From the above, it is seen that except for additional feature in column No.2, there is no other distinction between a digital photocopier and a analog photocopier. This factual position is not being seriously contested by the appellant but the appellant would seek to bring their goods under the category 'freely importable' because they are capital goods. This contention was rejected by the Tribunal after taking note of the functionality of the machine which was imported and after taking note of the various Customs Tariff Headings and pointed out that photocopying machines are classified under various Tariff Headings such as 8443 3920, 8443 3930, 8443 3940, 8443 3950. Thus, it was pointed out that photocopying machines do not have any single entry in Tariff and copying machines whether or not combined with printers and facsimile machines are classified elsewhere as also machines which perform two or more functions of printing, copying or 19/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 facsimile transmission as in the case of the imported goods. Further the Tribunal noted that DGFT notification No.31/2005 dated 19.10.2005 uses the expression “photocopier machines” and therefore, there is no warrant to read the expression appearing in the DGFT notification as conforming to any one particular expression used in the Tariff as these expressions are not identical and no Tariff item is mentioned in the DGFT notification.
21.The appellant seeks to take forward his case by referring to the decision in the case of Anand Impex. Firstly, the said decision was rendered in a writ petition filed by the importer seeking provisional release of the goods as the goods were detained by the customs authorities. The finding rendered in the writ petition cannot in any manner advance the case of the appellant as there was no adjudicatory process followed in the said case and we are not persuaded by the observations made therein as there was no substantial question of law which was decided in the said case. The appellant faults the Tribunal for having not followed the decision of the co- ordinate Bench of the Tribunal. The Tribunal has given elaborate reasons as to why the earlier decision of the co-ordinate Bench of the Tribunal would not be applicable and faulted the co-ordinate Bench of the Tribunal in 20/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 Shivam International in not following the earlier decision of the co- ordinate Bench of the Tribunal not referring the matter to the Larger Bench of the Tribunal.
22.The reason assigned by the Tribunal for not following the earlier decision is perfect and justified. In fact, the decision in Shivam International appears to be not adhering to the principle of judicial discipline in following the earlier decision and taking a different view. In any event, a simple and straight forward reading of para 2.17 of the FTP, as is required to be done, and by applying the common parlance test import of all second hand goods are restricted, second hand capital goods alone are freely importable and para 2.17 specifically states that second hand photocopier machines will only be allowed against a license. The attempt of the appellant to state that the goods imported by them are not photocopiers has to necessarily fail because the common parlance test will also encompass the functionality test of the imported machinery and the Tribunal after elaborately analysing the functionality found that all features of a photocopier in the imported machinery. Therefore, the words photocopier machines occuring in para 2.17 cannot be given a restrictive meaning and if 21/24 https://www.mhc.tn.gov.in/judis/ CMA.No.4719 of 2019 the common parlance test is applied as the appellant wants us to do, we are to necessarily hold that the goods imported are restricted and cannot be freely imported without a license.
23.The Tribunal is right in holding that the decision in Xerox India Ltd., could not have been applied to the case on hand as what was dealt therein was a classification dispute as to whether the multi functional machines would fall under CTH 8479.89 [Residual Heading] as claimed by the revenue or CTH 8471.60 as claimed by the importer therein and on facts, the Hon'ble Supreme Court held that the predominant components are relating to printing function and therefore, it was held that they are classifiable under CTH 8471.60. Further, the Tribunal was right in holding that in the amending notification No.31/2005 dated 19.10.2005, there is no reference to import restriction being limited to photocopying machines falling under any particular tariff item and should encompass second hand photocopier machines of all kinds to be placed in the restricted category. In the light of the above discussing, we hold that the Tribunal rightly rejected the case of the appellant.
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24.In the result, the appeal fails and is dismissed and the substantial questions of law are answered against the appellant. No costs. Consequently, connected miscellaneous petition is closed.
(T.S.S.,J.) (R.N.M.,J.)
17.02.2021
Index: Yes/No
Internet:Yes/No
Speaking Judgment/Non speaking Judgment
cse
To
1.The Customs, Excise & Service Tax
Appellate Tribunal, South Zonal Bench,
Shasthri Bhawan Annexe, 1st Floor,
26, Haddows Road,
Chennai - 600 006.
2.The Commissioner of Customs (Imports),
Customs House, No.60, Rajaji Salai,
Chennai – 600 001.
23/24
https://www.mhc.tn.gov.in/judis/
CMA.No.4719 of 2019
T.S.SIVAGNANAM,J.
AND
R.N.MANJULA,J.
cse
Pre-delivery judgment in
C.M.A.No.4719 of 2019
and C.M.P.No.26818 of 2019
17.02.2021
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