Essential character governs classification of unassembled television components as complete colour television sets under tariff rules.

Colour television sub-assemblies cleared from the factory and needing only final fitting at the buyer's end were treated as complete colour television sets under Chapter 85. Applying Rule 2(a) of the General Rules for Interpretation, goods cleared in unassembled form but retaining the essential character of the finished article are classified as that finished article. The note states that the supplies consisted of matched cabinets, picture tubes, chassis and related components for specific sets, and that the buyer's role was limited to assembly and connection, so the goods were not mere sub-assemblies. The classification adopted by the Revenue was therefore upheld.

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Issues: Whether colour television sub-assemblies cleared from the assessee's factory, and requiring only assembly at the buyer's end, were classifiable as complete colour television sets under Chapter 85 of the Central Excise Tariff Act, 1985.

Analysis: The goods cleared from the factory consisted of cabinet assemblies, picture tubes, chassis and related components supplied in matched quantities for specific television sets. The buyer's activity was limited to fitting and connection, without substantial manufacturing. Applying Rule 2(a) of the General Rules for the Interpretation of the First Schedule to the Central Excise Tariff Act, 1985, goods having the essential character of the finished article are to be treated as the complete article even if cleared unassembled or disassembled. The earlier Supreme Court ruling on similar television assemblies governed the classification dispute, and the factual distinction suggested by the assessee did not alter the essential nature of the goods.

Conclusion: The goods were correctly classified as complete colour television sets, not as mere sub-assemblies, and the classification adopted by the Revenue was upheld.

Ratio Decidendi: Goods cleared in unassembled form but possessing the essential character of the finished product are classifiable as the finished product under interpretative Rule 2(a).

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