Exemption for paper supplies upheld where the purchaser was a government-owned body and the purchase order conditions were satisfied.

Writing and printing paper supplied under Chapter 48 qualified for exemption under sub-heading 4802.10 because the Delhi Bureau of Text Books was wholly owned and organised by the Government of NCT of Delhi. The objection that the Bureau was not a Government-owned body failed, and the purchase order was treated as valid because it was countersigned by the Chairman, who was the Special Secretary of Education, Government of NCT of Delhi. The supply was therefore held to fall within the exemption entry, and denial of the benefit was unjustified.

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Issues: Whether the appellants were entitled to exemption under sub-heading 4802.10 of Chapter 48 of the Central Excise Tariff Act on supplies made to the Delhi Bureau of Text Books, and whether the conditions in Para 1(a) of the Note appended to that sub-heading were satisfied.

Analysis: The goods supplied were writing and printing paper falling under Chapter 48. The record showed that the Delhi Bureau of Text Books was wholly owned and organised by the Government of NCT of Delhi, so the objection that it was not a Government-owned body was unsustainable. Although the purchase order was initially placed by the Secretary of the Bureau, it was subsequently countersigned by the Chairman, who was the Special Secretary of Education, Government of NCT of Delhi. On that basis, the requirement that the purchase order be placed by the specified authority was treated as fulfilled. The appellants had therefore supplied the goods against a valid order from the eligible State-owned body within the scope of the exemption entry.

Conclusion: The appellants were entitled to the exemption under sub-heading 4802.10, and the denial of the benefit was unjustified.

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