Madras High Court
M/S.Unitech Enterprises vs The Customs on 17 February, 2021
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.
1/24
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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”
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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
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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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CMA.No.4719 of 2019
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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CMA.No.4719 of 2019
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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CMA.No.4719 of 2019
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
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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
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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
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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
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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.
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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
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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
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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
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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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CMA.No.4719 of 2019
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
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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
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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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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
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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
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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
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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.
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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
https://www.mhc.tn.gov.in/judis/
