Unfinished armatures requiring further processing are not assessable as finished motor parts under the tariff entry.

Goods cleared in an unfinished condition were held not to be complete armatures exigible to duty under Item 30(4) of the First Schedule to the Central Excises and Salt Act, 1944. Inspection showed that further processing such as grinding or turning of the commutator and varnishing was necessary before the goods could function as armatures in D.C. motors, and that processing was carried out by buyers after clearance. Because the goods were not fit for use as armatures when removed from the factory, they could not be assessed as finished electric motor parts under the tariff entry.

---

---

Issues: Whether the goods cleared by the appellants were complete and finished armatures exigible to duty under Item 30(4) of the First Schedule to the Central Excises and Salt Act, 1944, or only unfinished armature windings requiring further processing before they could function as armatures in D.C. motors.

Analysis: On inspection of the samples and consideration of the material on record, the goods manufactured by the appellants were found to require further processing by way of grinding or turning of the commutator and varnishing before they could be put to use as armatures. That processing was not undertaken in the appellants' factory and was done by the buyers after clearance. The goods, in the condition in which they were removed, were therefore not complete armatures fit for use as such and could not be treated as finished parts of electric motors for the purpose of duty.

Conclusion: The goods were not liable to central excise duty under Item 30(4) of the First Schedule to the Central Excises and Salt Act, 1944, and the appeal succeeded.

Ratio Decidendi: Goods cleared in an unfinished condition, which require substantial further processing before becoming usable as the described excisable article, are not assessable as the finished article under the tariff entry.

---