Excise treatment of split-supplied batteries under Notification 68/86 requires full examination of Rule 2(a) and exemption scope.

Stationary batteries cleared without electrolyte, with electrolyte supplied separately for later filling, required fresh examination for exemption under Notification No. 68/86 and treatment as a single excisable article under Rule 2(a). The battery was described as a functional unit, and the separate supply of electrolyte for transport convenience did not by itself resolve the exemption question. Because the lower authority had not properly examined the notification and interpretative rule, the impugned order was set aside and the matter remanded for de novo adjudication, with the assessee obtaining the benefit of remand.

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Issues: Whether stationary batteries cleared without electrolyte, but with electrolyte supplied separately for later filling, were entitled to exemption under Notification No. 68/86, and whether the goods could be treated as one entity for excise purposes under the interpretative rules.

Analysis: It was undisputed that the electrolyte was intended to be filled into the battery and that, if supplied already filled, the battery would qualify for the notification benefit. The relevant question was whether separate supply of electrolyte for transport convenience altered the excise treatment. The battery was described as a functional unit consisting of plates, terminals and container, with the electrolyte being the remaining component required for use. The lower authority had not examined the applicability of Rule 2(a) of the interpretative rules or the scope of the notification in depth.

Conclusion: The matter required fresh examination and the impugned order could not be sustained. The order was set aside and the case was remanded for de novo adjudication, with the assessee obtaining the benefit of remand.

Ratio Decidendi: Where goods are cleared in a split form but are intended to function as a single complete article, their excise treatment and exemption eligibility must be examined with reference to the applicable interpretative rule and the notification as a whole.

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