Customs Duty Exemption Upheld for Lithium-ion Battery Parts Used in Power Banks; Manufacturing Definition Key.

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....The appellant imported parts, components, and accessories at a concessional rate of customs duty under Notification No. 50/2017-Cus dated 30.06.2017, Entry No. 512, for manufacturing Lithium-ion batteries. However, it was alleged that the imported goods were used for manufacturing power banks instead. The term "manufacture" in the notification must be interpreted considering Rule 3(e) of the IGCR Rules, 2017. A cell is a single unit that converts chemical energy into electrical energy, while a battery is a group of cells. The term "manufacture" in Rule 3(e) is satisfied when a battery emerges as a distinct product from its components, i.e., individual lithium cells and others. The exemption under Entry No. 512 is available when the imported.........