Television components and manufacture test led to concessional duty relief where imported parts were not a complete set.

Imported television parts were treated as separate components classifiable under different headings, not as a complete television in semi-knockdown condition. On the facts, the record did not show that all parts of a finished television had been imported together, and assembly of the imported components into a television was held to amount to manufacture. The denial of concessional duty benefit was therefore based on an incorrect assumption that no new product emerged, and the issue was decided in favour of the respondent.

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Issues: Whether the imported television parts were brought in as a semi-knockdown complete set and whether assembly of the imported components amounted to manufacture so as to qualify for concessional duty benefit.

Analysis: The imported items were found to be individual components separately classifiable under different headings, not a complete television in semi-knockdown condition. The record did not establish that all components of a finished television had been imported together. On the facts, assembly of the imported parts into a television constituted manufacture, and the rejection of the application proceeded on an incorrect assumption that no new product emerged.

Conclusion: The issue was decided in favour of the respondent and against the revenue.

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