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Issues: Whether regulators supplied along with ceiling fans of 104 cm sweep were to be assessed at the separate rate prescribed for regulators under Notification No. 46/84-C.E., or at the rate applicable to the ceiling fan as part of the fan.
Analysis: Item 33 of the tariff had already treated electric fans and regulators together, and the earlier judicial and administrative understanding consistently regarded the regulator as an integral component of the fan. The notification provided a separate rate for regulators to cover cases where a regulator was sold independently. Where the regulator was supplied with the fan and its value was included in the price of the fan, the regulator did not lose its character as part of the fan. The separate rate could not be applied to a regulator sold with the fan, because the fan was not complete without it and the notification was intended to address standalone sales of regulators.
Conclusion: The separate 15% ad valorem rate for regulators applied only when the regulator was sold without the electric fan. Regulators supplied with the fan were assessable with the fan at the rate applicable to the fan proper, in favour of the assessee.
Ratio Decidendi: A regulator supplied with a ceiling fan is an integral part of the fan, and a separate tariff rate for regulators applies only to independent sales of regulators.