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Issues: Whether the imported rotor claw forgings had attained the essential character of finished articles so as to be classifiable under the heading for alternator parts by application of Rule 2(a), or whether they remained rough steel forgings classifiable as such.
Analysis: The goods were examined along with the drawings and were found to require further operations such as drilling, machining and other finishing processes before fitment. The facts showed that they had not reached the approximate shape and outline of the finished article in the sense contemplated by Rule 2(a). The distinction drawn in the relied upon precedent was that Rule 2(a) applies only where the imported article has the essential character of the finished product, whereas forgings needing substantial further work remain forgings and do not become finished parts merely because they are made to a specific drawing. On the facts found, the earlier authority favourable to the Revenue was held distinguishable.
Conclusion: Rule 2(a) was not applicable, and the goods were correctly treated as rough steel forgings rather than finished alternator parts.