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Issues: Whether the imported components and raw materials were eligible for Project Import benefit under Tariff Heading 84.66 when they were claimed to be required for testing machinery and for completing the initial setting up of the plant.
Analysis: The import claim was examined in the context of the project not having reached complete initial set-up and of the goods being required for testing machinery rather than for a finished end-product. It was accepted that components and raw materials could fall within the project import benefit if they were necessary for setting up the plant and were covered by the import licences. The Revenue's request for fresh verification was declined because the matter was old, the specific factual claim had not been rebutted, and the lower appellate authority's reliance on the industrial authority's certificate was not shown to be unsupported by adequate contrary evidence.
Conclusion: The imported items were held to be eligible for the Project Import benefit under Tariff Heading 84.66, and the Revenue's appeal was rejected.
Ratio Decidendi: Components and raw materials imported for use in testing machinery that is necessary for completing the initial setting up of a project plant are permissible under Project Import benefits, particularly where the import is covered by the relevant licences and the factual claim is not effectively rebutted.