Unassembled PVC doors and windows classified as finished goods under Rule 2(a) for site assembly

PVC doors and windows cleared in unassembled form, together with profiles, channels and accessories for site assembly, are to be classified as the complete article under Rule 2(a) where they possess the essential character of finished doors and windows. The records showed that the goods were not mere running lengths or generic intermediate inputs, but specified sets intended for simple fixing at the customer's premises. On that basis, sub-heading 3925.20 applied and sub-heading 3925.99 did not, with the classification issue resolved in favour of the assessee.

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Issues: Whether PVC doors and windows cleared in unassembled condition, together with their profiles, channels and accessories, were classifiable as complete or finished doors and windows under Tariff sub-heading 3925.20 by applying Rule 2(a) of the General Rules for the Interpretation of the Schedule to the Central Excise Tariff Act, 1985.

Analysis: The goods were cleared as specified sets of profiles, channels, beadings and accessories meant for assembly at the customer's premises into doors and windows of predetermined dimensions and design. The invoices and supporting records showed that the goods were not mere running lengths or generic intermediate products, but components presented in unassembled form for simple fixing operations at site. Under Rule 2(a), goods presented unassembled or disassembled are to be classified with reference to the complete or finished article, and the Explanatory Notes to the HSN reinforce that such articles remain classifiable in the same heading where only simple assembly is involved. The earlier assumption that the goods were cleared in running length was found unsupported, and the lower appellate reasoning based on CKD was held to be inapposite.

Conclusion: The unassembled PVC doors and windows were classifiable under sub-heading 3925.20 and not under sub-heading 3925.99, and the assessee's claim succeeded.

Final Conclusion: The impugned classification orders were set aside and the appeals were allowed, resulting in relief to the assessee on classification and the related duty consequence.

Ratio Decidendi: Articles presented unassembled for simple assembly at the customer's premises must be classified as the complete or finished goods if they possess the essential character of those goods under Rule 2(a).

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