Rule 2(a) of the General Rules for Interpretation applies only...

Rule 2(a) of the General Rules for Interpretation applies only where imported goods, as presented, already have the essential character of the complete article. On the facts described, fragmented components were imported in multiple consignments, critical parts such as batteries were absent from the subject shipments, and the Department could not establish consignment-wise correlation showing a complete electric vehicle; reclassification as CKD e-bikes under heading 8711 was therefore unsustainable. The extended limitation period was also unavailable because the dispute was one of classification, the imports were within departmental knowledge, and no fraud or suppression was shown. Confiscation, redemption fine, and penalties failed with the merits and limitation challenge.

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