Exemption for cycle parts extends to bead rings embedded in tyres, as a part of a part remains part of the whole.

Cycle tyre bead rings used in bicycle or cycle rickshaw tyres were treated as covered by the exemption for parts and accessories of bicycles and cycle rickshaws. The reasoning was that the tyre is an essential component of the cycle assembly, and a bead ring embedded in that tyre remains an essential part of the whole; a part of a part is also a part of the whole. The exemption was not denied merely because the bead ring was not an independently visible bicycle part. The notification therefore applied to the goods, and the Revenue's appeal failed.

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Issues: Whether cycle tyre bead rings, classified under Tariff Heading 7308.90, were entitled to the benefit of the exemption granted by Notification No. 62/86 dated 10-2-1986 as amended by Notification No. 104/86-C.E. dated 27-2-1986 for parts and accessories of bicycles and cycle rickshaws.

Analysis: The goods were admittedly used in the tyre of a bicycle or cycle rickshaw. Since the tyre itself is an essential component of the bicycle or cycle rickshaw, the bead ring embedded in that tyre was treated as an essential part of the cycle assembly. The governing principle applied was that a part of a part is also a part of the whole, and the exemption could not be denied merely because the product was not an independently visible part of the bicycle or cycle rickshaw.

Conclusion: The bead rings were covered by the exemption notification and the Revenue's appeal failed.

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