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Issues: Whether hubs of windmills, extender for hub, and support to hub, though cleared in unfinished or unmachined casting form, were eligible for exemption as parts of windmills under Notification No. 205/88-C.E. dated 25.05.1988.
Analysis: The exemption entry covered parts of windmills and did not make tariff classification a condition for availment of the benefit. The dispute turned on whether the goods in question could be regarded as windmill parts despite being unmachined castings. Reliance on classification under sub-heading 7325.10 was not determinative because the notification was not linked to tariff headings. The applicable interpretative principle relating to incomplete goods having the essential characteristics of finished goods supported treatment of the items as the relevant finished parts. It was also significant that there was no case that, after further machining, the goods could be used for any purpose other than as windmill parts.
Conclusion: The disputed goods were parts of windmills eligible for exemption under Notification No. 205/88-C.E. dated 25.05.1988; the issue was decided in favour of the assessee.