Imported equipment and materials for lithium-ion cell production line qualified for concessional duty, subject to IGCR, 2022 end-use proof.

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....Thirteen imported items used in a lithium-ion cell production line were assessed for tariff classification and eligibility to concessional duty under a use-based exemption for "parts, sub-parts, inputs or raw materials" for manufacture of lithium-ion cells. Given their functional indispensability in cell manufacturing and the chapter-neutral wording and object of the exemption, they were held squarely covered, applying the principle that strict construction of exemptions must not defeat legislative purpose; benefit was allowed subject to strict IGCR, 2022 compliance and actual end-use in cells under tariff item 8507 60 00. The adhesive tapes were classified under 3919 10 00; polyether-modified polysiloxane under 3910 00 90; POLYSOL LB-150J under 3903 90 90; and PVDF under 3904 69 90 - AAR....