Earthquake-relief exemption broadly covers finished vehicles and related components; prima facie waiver of pre-deposit was granted.

The earthquake-relief exemption was read broadly to cover goods cleared for that purpose to the Government of Gujarat and notified agencies, including fully manufactured vehicles supplied for relief use. A narrow attempt to split finished vehicles into chassis, bodies, accessories and other intermediate components was rejected as impermissible. Construing the phrase "all goods" in light of the notification's object, the intermediary goods used in making the final vehicles were also treated as covered at the prima facie stage. On that basis, the assessee was found to have a strong case on merits, and waiver of pre-deposit with stay of recovery was granted.

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Issues: Whether the exemption notification for earthquake relief covered the fully manufactured vehicles and their constituent parts and whether the appellants had made out a strong prima facie case for waiver of pre-deposit and stay of recovery.

Analysis: The notification exempted "all goods" cleared for earthquake relief to the Government of Gujarat and notified agencies. The dispute concerned fully finished vehicles supplied for that relief purpose, and the attempt to split the finished vehicles into chassis, bodies, accessories and other intermediary components was held to be impermissible. The expression "all goods" was construed broadly in light of the object of the notification, and the intermediary goods that went into the manufacture of the final vehicles were treated as covered by the exemption. On that basis, the appellants were found to have a strong case on merits for interim relief.

Conclusion: The exemption was held applicable at the prima facie stage to the goods in question, and waiver of pre-deposit with stay of recovery was granted in favour of the assessee.

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