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4. Shri A.R. Madhav Rao, ld. Advocate for the appellants invited our attention to the catalogue pertaining to the imported item, which de-scribed the various functional features of the goods as follows :

"a Printer with Colour Output a Scanner with OCR a Fax with Hi-speed Modem a Copier with Zoom Facility a PC Fax"

Ld. Advocate also submitted that, out of the 59 parts of the machine, 35 parts [59%] related to the printing function, 13 parts [22%] related to the scanning function and 11 parts [19%] related to the fax function. 59% of the total number of parts related to the printing function. The product could do printing both in black and colour, the printing speed being 3 ppm (pages per minute), which speed conformed to the industrial standards for printing but was sub-standard for photocopying. Even for copying purposes, the scanner was first used for scanning the original document and then the printer was used for printing the scanned image. In other words, the machine's printing function was used even for its utility as a copier. The product with its inbuilt software etc. was specially designed for connectivity to Automatic Data Processing (ADP) machines through parallel port cables which came with the machine itself. For all these reasons, ld. Counsel submitted, the machine was essentially and principally a printer and it required to be classified under CTH 8471.60 as an input-output unit of ADP machine. He relied, in this connection, on Chapter Note 7 to Chapter 84 of the Customs Tariff as well as Note 5(D) read with Note 5(B)(b) & (c) to the said Chapter. Ld. Advocate also relied on the relevant HSN Explanatory Notes. Counsel also relied on two expert opinions on classification of similar products, given by US authorities. One of these opinions was rendered by the Director, National Commodity Specialist Division, in respect of a machine described as "Xerox Document Work Centre Pro 535" and the same was given in letter dated 26-9-1996, copy of which is available on record. In the said letter, it was stated that the above machine incorporated features which allowed it to function as a facsimile transceiver, digital scanner, telephone transceiver and local photocopier. It was also stated that the goods incorporated an electrostatic laser print engine, capable of printing ADP output from a central processing unit (CPU) at a rate of four pages per minute. It was further stated that the machine was a composite goods made up of different components which was described under different provisions of the Harmonised Tariff Schedule [HTS]. Although the device was capable of use as a facsimile transceiver, digital scanner, telephone transceiver and local photocopier, its principal use appeared to be as an output printer for ADP machines. On this basis, it was opined that the D-535 multifunction printer would be classifiable under sub-heading 8471.60.6200, Harmonized Tariff Schedule of the United States (HTS). The other opinion was contained in letter dated 30-7-1997 of the Chief, Metals and Machinery Branch, National Commodity Specialist Division, and the same was in respect of "Canon" CLC 1000, which was also a multifunctional colour laser copier/printer. The machine was capable of printing @ 31 pages per minute. It was opined that CLC 1000 multifunctional colour laser copier/printer appeared to be principally designed for use as a colour printer for ADP systems and networks. The digital copying function was a subsidiary function which also utilised the laser printing components of the product. It was categorically opined that although the device was capable of use as a digital photocopier, its principal use appeared to be as an output printer for ADP machines. On this basis, it was advised that the applicable sub-heading for the product under the Harmonized Tariff Schedule of the United States would be 8471.60.6100. Ld. Counsel pointed out that Legal Note 7 of Section XVI of the HTS of the United States was pari materia with Chapter Note 7 to Chapter 84 of the Indian Customs Tariff and that the above expert opinions, based on the aforesaid Legal Note 7 would be applicable to the impugned goods in the instant case, in which the appellants relied on Chapter Note 7 ibid and contended that the goods, being multifunctional, required to be classified on the basis of its principal and essential function namely printing. Ld. Counsel, therefore, prayed for setting aside the impugned order and for classification of the goods under CTH 8471.60.