Spectacle lenses in semi-finished form retained their identity and qualified for exemption under the notification.

Semi-finished spectacle lenses were held classifiable as spectacle lenses, not to be treated as ineligible ophthalmic blanks merely because further finishing was required for a particular customer. Applying the Supreme Court decision in the assessee's own case, the earlier view denying exemption was found erroneous because the commercial identity of the goods remained spectacle lenses. The benefit of Notification No. 6/2006-CE dated 01.03.2006 was therefore held admissible, the classification below was not sustained, and consequential relief followed.

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Issues: Whether semi-finished spectacle lenses were correctly classified as other optical elements, and whether the benefit of Notification No. 6/2006-CE dated 01.03.2006 was admissible.

Analysis: The dispute was covered by the Supreme Court decision in the assessee's own case, which held that the imported goods were spectacle lenses to be finished for a particular customer and could not be denied exemption merely because they were described as semi-finished. The earlier view treating them as ophthalmic blanks or as ineligible for the notification was found to be erroneous.

Conclusion: The classification adopted below was not sustained, and the exemption under Notification No. 6/2006-CE dated 01.03.2006 was held admissible in favour of the assessee.

Final Conclusion: The appeals succeeded and the assessee obtained consequential relief on the basis that the goods were entitled to the claimed exemption.

Ratio Decidendi: Goods that are to be finished and used as spectacle lenses cannot be denied exemption merely because they are imported in semi-finished form, where the substance and commercial identity of the goods remain spectacle lenses.

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