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3. The Commissioner observed that all the imported and indigenous components had separate individual functions and were parts of transmission apparatus for radio telephony. Systematic assembly of the above components had brought into existence intermediate products, such as Mobile Switching Centres, Base Station Controllers, and Base Transceiver Stations. Integration of these in turn had brought into existence new goods known as transmission apparatus for radio telephony. ECPL had assembled components and integrated those into new goods known as 'transmission apparatus for radio telephony' (TART). These goods fell under Chapter Heading 85.25 of the Central Excise Tariff. The apparatus was different from its components, had a new name, characteristics and use. The Commissioner found that, Note 6 to Section XVI of the Central Excise Tariff Act. 1985, provides that conversion of an article which is incomplete or unfinished but having essential character of the complete or finished article (including blank, that is an article, not ready for direct use, having approximate shape or outline of the finished article or part, and which can only be used, other than in exceptional cases, for completion into the finished article or part) into complete or finished article shall amount to manufacture.