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Issues: Whether belt conveyor supplied in knocked down condition, without the belt, was classifiable under Heading 84.28 as a complete belt conveyor or under Heading 84.31 as parts of belt conveyor.
Analysis: The customer had ordered the entire conveyor system consisting of drive unit, take-up unit, intermediate structure and tail unit, while the belt was not part of the order and was to be procured from the market and attached at site. Rule 2(a) of the Interpretative Rules to the Central Excise Tariff Act, 1985 treats incomplete or unfinished goods as complete goods if they have the essential character of the complete article, including goods removed unassembled or dismantled. On the purchase order and drawings, the supplied structure retained the essential character of a belt conveyor, and the absence of the belt did not convert it into mere parts.
Conclusion: The goods were correctly classifiable under Heading 84.28 as belt conveyors and not under Heading 84.31 as parts of belt conveyors.