Import licensing for knocked-down components turns on whether policy deems parts to be complete goods; confiscation failed here.

Components of video display units imported in knocked-down form were treated as parts, not complete display units, because no deeming provision in the import policy or tariff rules then in force converted them into finished goods. In the absence of such a rule, each component had to be assessed on its own for import eligibility. The relevant departmental rule had not formed part of the import policy at the time of import in 1996, so the goods did not require a licence and confiscation was unsustainable.

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Issues: Whether components of video display units imported in 1996, without a licence, could be treated as complete display units so as to require a licence and justify confiscation.

Analysis: The imported goods consisted of components of video display units and not complete units. In the absence of a deeming provision treating all or major components as the finished article, each component had to be considered on its own for import eligibility. The principle applied was that parts and accessories imported in knocked-down form remain parts and accessories unless the relevant policy or tariff rule expressly deems them to be a complete machine. The rule relied upon by the department had not become part of the import policy at the time of import in 1996.

Conclusion: The import did not require a licence and the confiscation order was unsustainable.

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