Customs exemption extends to authorised imports made on behalf of a Public Funded Research Institution under the notification and circular.

Customs exemption under Notification No. 51/96 applies to goods imported by an authorised importer on behalf of a Public Funded Research Institution when the goods are meant for delivery to that eligible institution. The notification covered specified institutions, and the Board's Circular No. 27/2003-Cus. clarified that the benefit could extend even where the importer was not itself the named institution, provided the import was for the institution's use. On that reading, the conditions were satisfied for goods imported on behalf of VSSC, and the duty demand was not sustainable.

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Issues: Whether exemption under Customs Notification No. 51/96 dated 23-07-1996 was available when the goods were imported by an authorised importer on behalf of a Public Funded Research Institution.

Analysis: The notification granted exemption to specified goods imported by the institutions named in the relevant table, including a Public Funded Research Institution. The Board's Circular No. 27/2003-Cus. clarified that the benefit could still be extended where the goods were imported by a person other than the specified institution, provided they were meant for delivery to that institution. As the goods were imported by the respondent for and on behalf of VSSC, a Public Funded Research Institution, the conditions of the notification, read with the Board's clarification, were satisfied.

Conclusion: The exemption was rightly extended to the respondent and the Revenue's challenge failed.

Final Conclusion: The demand of duty was not sustainable and the Revenue appeal stood dismissed.

Ratio Decidendi: A customs exemption notification intended for a specified research institution can be applied to an authorised importer acting on behalf of that institution where the goods are meant for delivery to the eligible institution and the Board's clarification supports such extension.

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