Krishan Kalani Chief Operating Officer vs Ce & Cgst Noida on 16 October, 2025
27. The facts in the case of Sony India Ltd. (supra)
may be distinguished in this respect. In that case, the
assessee had imported different parts of television
sets in 94 different consignments. The said parts were
imported separately in bulk, and thereafter, the
process of matching, numbering and assembling was
carried out once they were in the possession of the
assessee. Therefore, it may be seen that what the
assessee had imported in that case were merely
various parts which could not yet be identified and
distinguished as individual Television Receivers such
as the parts transported by the appellant in this case.
The said decision is, therefore, distinguishable on
facts.