JUDGMENT :

SURYA KANT, J.

1. The question that arises for our consideration pertains to correct classification of Automatic Data Processing Machines (hereinafter ‘ADP’) which are popularly known as ‘All-in-One Integrated Desktop Computer’ (hereinafter ‘Concerned Goods’) under the First Schedule to the Central Excise Tariff Act, 1985 (hereinafter ‘First Schedule’).

FACTS

2. The Appellants imported certain units of the Concerned Goods and classified them under ‘Tariff Item 8471 50 00’ as per the prevalent self-assessment procedure. During subsequent examination by the Custom Authorities, the Concerned Goods were classified under ‘Tariff Item 8471 30 10’ which was later confirmed by the Assistant Commissioner of Customs and Commissioner of Customs (Appeal). These findings were further affirmed by the Customs, Excise and Service Tax Appellate Tribunal (hereinafter ‘CESTAT’), West Zonal Bench, Mumbai vide the impugned judgments dated 19.12.2018 and 24.06.2019.

3. While the rate of duty is same under both the Tariff Items, the method of computing them is different. Goods under ‘Tariff I