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(Made by R.SUDHAKAR,J.) The above Tax Case (Revisions) are filed by the assessee as against the order of the Tamil Nadu Sales Tax Appellate Tribunal raising the following substantial questions of law:

"A. Whether the multi-function network printers sold by the Appellant under the Canon product "Image Runner" are to be classified under Schedule I, Part B, Entry 18(i) taxable at 2% (10% without C Form) (as contended by the Appellant) or under Schedule I, Part C, Entry 13(i) taxable at 4% (12% without C form) (as held by the Sales Tax Appellate Tribunal)?

I. Whether the Tribunal was correct in holding that the Disputed Printers should be classified under Schedule I, Part C, Entry 13(i) and not Schedule I, Part B, Entry 18(i) after holding that the Disputed Printers were "admittedly" multi functional printers with "additional functions" of copying and faxing?

J. Whether the Tribunal erred in classifying the Disputed Printers under Schedule I, Part C, Entry 13(i) without refuting the appellant's contention that the Disputed Printers were laser printers (which fall under Schedule I, Part B, Entry 18(i) with additional copying and faxing features which were completely dependent on the laser printing components for functioning?

5. We have heard the learned counsel for the petitioner and the learned Standing Counsel appearing for the respondent and perused the order passed by the Tribunal and the authorities below.

6. Even though several questions of law have been raised by the petitioner for consideration, the learned counsel on either side concur that the core issue around which the entire case revolves is: Whether the Image Runners (Multi-function Network Printers) sold by the assessee are to be classified under Schedule I, Part B, Entry 18(i) as claimed by the assessee or under Schedule I, Part C, Entry 13(i) as held by the Tribunal? 7.1. Before adverting to the merits of the case, it is apposite to refer to the decision of the Supreme Court in Xerox India ltd. case, referred supra. In that case, the assessee's claim was that the import of multi-functional machines capable of discharging number of functions would fall under sub-heading 8471.60 of the Act, whereas the Department of Customs classified the said imported machines under chapter heading 8479 (residuary heading). The importer was unsuccessful before the Original Authority, First Appellate Authority and before the Tribunal. Therefore, the importer went before the Supreme Court.

"6.3 A MFP (Multi Function Product/Printer/Peripehral), multifunctional, all-in-one (AIO), or Multifunction Device (MFD), is also an office machine connected to a computer which incorporates the functionality of multiple devices in one, so as to have a smaller footprint in a small business or office setting or to provide centralized document management/ distribution/ production in a large-office setting. A typical MFP may act as a combination of some or all of the following devices, viz., E-mail, Fax, Photocopier (Xerox), Printer & Scanner. The products, viz., Digital Multi Function Devices of several brands such as Canon, Sharp, and Konica Minolta, imported and marketed by are connectible to the computers to print, scan and copy, facsimile and fax the documents. As per the details available in the brochure furnished along with the application by the applicant-firm of the imported multifunction devices, it is found that they are predominantly usable, stands connected to the computers to perform the tasks for the performance of which the machines are so designed and programmed."