Semi-finished spectacle lenses retained their identity for exemption and classification despite needing further finishing.

Semi-finished spectacle lenses retained their essential character as spectacle lenses for classification purposes because they were imported as power lenses and required only further finishing to suit a customer's prescription. Classification under the residuary heading was therefore unsustainable, and the exemption under Notification No. 6/2006-CE applied. The analysis followed the assessee's own earlier case, which had already been settled by the Supreme Court and applied by the Tribunal in prior proceedings. On that basis, the appeals succeeded and consequential relief was granted.

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Issues: The issue was whether semi-finished spectacle lenses were classifiable as spectacle lenses and eligible for exemption under Notification No. 6/2006-CE dated 01.03.2006.

Analysis: The goods were imported as power lenses and were treated as semi-finished only because they required finishing before customization to the prescription of a particular customer. Such lenses could not be treated as merely semi-finished optical elements when their essential character remained that of spectacle lenses. The issue was already settled in the assessee's own case by the Supreme Court and followed by the Tribunal in earlier proceedings.

Conclusion: The classification under the residuary heading was not sustainable and the exemption notification was applicable. The issue was decided in favour of the assessee.

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

Ratio Decidendi: Goods that are only unfinished or to-be-finished spectacle lenses retain their identity as spectacle lenses for classification and exemption purposes, and cannot be denied the benefit of the exemption solely because they require further finishing.

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