1. The Appellant firm imported a consignment of what was described in the covering invoice as "Pole-end-plate forgings-Rough machined pole and plate forgings for generator parts Drg. No. 3-68-0006 through the port of Bombay. The Customs authorities classified the goods under heading No. 73.33/40 which read at the material time as follows :-

"73.33/40-other articles of iron or steel"

The appellants cleared the goods on payment of customs duty so assessed at 60% ad valorem (Basic Customs duty) plus 15% ad valorem (Auxiliary Customs duty). Later on, they filed a refunded claim before the Assistant Collector of Customs seeking re-assessment of the goods under Customs Notification No. 182/78 on the ground that the subject goods were required as parts for the assembly or manufacture of synchronous condenser of rating 30 MVAR.' The A.C. rejected the claim as unsubstantiated on the ground that the documentary evidence asked for by him was not produced by the Appellants. Against this order the appellants preferred an appeal which the, Appellate Collector of Customs rejected on the ground that the imported items were not finished items and therefore they could not be deemed as parts within the meaning of the Customs Notification No. 182/78. He also rejected the Appellant's contention that Rule 2(a) of the Rules for the interpretation of the Customs Tariff Schedule was applicable for interpretation of expressions occurring in notifications also. It is against this order that the appellants filed a revision application before the Central Government which stands transferred to the Tribunal under Section 131-B of the Customs Act and is to be disposed of by the Tribunal as if it were an appeal presented before it.

2. The claim for re-assessment of the imported pole-end-plate forgings is on two alternative grounds. First, the imported goods are specially designed component parts of generators in terms of Interpretative Rule 2(a) read with Heading No. 85.01(1) of the Customs Tariff Schedule. Alternatively, the goods also attract the provisions of Customs Notification No. 182/78 read with Interpretative Rule 2(a) as they are used in the assembly of synchronous condenser falling under Heading 85.01(1). The first of the two grounds referred to above was mentioned for the first time in the Revision Application. The Appellants submitted that they did not put forth this ground in the appeal before the Appellate Collector through oversight.

3. Appearing on behalf of the appellants, Shri Subramanian submitted that, in terms of Interpretative Rule 2(a), the imported goods, even though they were in the nature of unfinished or incomplete articles, were nevertheless to be deemed as finished or complete articles since they had the essential characteristics of the complete or finished articles. In this context, he referred to page 2, Vol. 1 of the Explanatory Notes to the Brussels Tariff Nomenclature containing a commentary on Interpretative Rule 2(a). The said commentary states that the provisions of the said rule also apply to blanks (unless they are specified in a particular heading) and the term "blank" is to be taken to mean an article, not ready for direct use, having the approximate shape or outline of the finished article or part, and which, other than in exceptional cases, can only be used for completion into the finished article or part. Shri Subramanian then proceeded to explain his point with reference to a technical write-up and a technical drawing purporting to show how the imported goods had the essential characteristics of the finished part of the synchronous condenser and how they would be used for fitment to the condenser after machining. Shri Subramanian submitted that Interpretative Rule 2(a) was applicable to the facts of the case and the imported goods should consequently be held to be component parts of synchronous condensers falling under heading 85.01(1) of the Customs Tariff Schedule. If, however, this contention was not acceptabl