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Issues: Whether the goods cleared by the assessee were switchboards covered by the CT-3 certificates and the exemption under Notification No. 123/81 dated 02.06.1981, or whether indoor panel with circuit breaker and circuit breaker were merely accessories outside the certificate coverage.
Analysis: The classification lists themselves described the goods as 33 KV switchboard with indoor panel and circuit breaker, and 6.6 KV switchboard with circuit breaker. The certificate description of 33 KV switchboard and 6.6 KV switchboard was read with the actual nature of the goods supplied. The assumption that indoor panel and circuit breaker were accessories was found to be incorrect, because these items constituted the switchboard itself. On that factual basis, the demand could not be sustained on the footing that the goods were outside the certificate coverage.
Conclusion: The goods were held to be covered by the CT-3 certificates, and the exemption was available to the assessee.
Final Conclusion: The appeal failed because the disputed items were not treated as separate accessories but as part of the switchboard description covered by the exemption.
Ratio Decidendi: Where the description in the certificate corresponds to the composite commercial identity of the goods, components forming part of that identity cannot be excluded as mere accessories for denying exemption.