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Issues: Classification of imported cordless phone with answering machine under Customs Tariff Act.
The judgment dealt with the classification of a "cordless phone with answering machine" imported by the appellants under the Customs Tariff Act. The main issue was whether the item should be classified under SH 8520.20 as claimed by the appellants or under SH 8517.11 as claimed by the Revenue. The appellants argued that the item should be classified as a telephone answering machine, while the Revenue contended it should be classified as a line telephone set with a cordless handset. The Tribunal analyzed the nature of the imported item, which was found to be a "line telephone set with cordless handset" that included an answering machine. The Tribunal referred to Note (3) to Section XVI of the Tariff Schedule, which states that machines designed for performing complementary functions should be classified based on the component or machine performing the principal function. In this case, the equipment was primarily designed for telephony, with the answering mechanism being complementary. Therefore, the answering machine component was considered incidental to the principal function of telephony performed by the cordless handset and line telephone set. Based on the above analysis, the Tribunal concluded that the entire equipment imported by the appellants should be classified as a "line telephone set with cordless handset" under SH 8517.11, not as a telephone answering machine under SH 8520.20. The decision of the lower appellate authority was upheld, and the appeal was dismissed. The judgment emphasized the importance of considering the principal function of the equipment for classification purposes and disregarding complementary functions in such cases.
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