Consumables for research exemption does not extend to unglazed vitrified ceramic tiles where their true character is not supported.

Unglazed vitrified ceramic tiles were held not to qualify as "consumables" for research purposes under Notification No. 10/97, because the term applies only to consumables connected with scientific and technical instruments, apparatus, accessories or spare parts used in research. A certificate describing the goods as consumables was insufficient to change their true character, especially where the certifying authority lacked expertise to classify them as such. Exemption was therefore denied and the earlier finding in favour of the assessee was reversed.

---

---

Issues: Whether unglazed vitrified ceramic tiles could be treated as consumables for research purposes so as to qualify for exemption under Notification No. 10/97 dated 1-3-1997.

Analysis: The notification granted exemption only to specified goods used for research purposes, namely scientific and technical instruments, apparatus, accessories, spare parts and consumables. The expression "consumables" had to be understood in the context of items required for such research instruments and appliances. The tiles in question were found, on the material before the Tribunal, to be incapable of being treated as consumables required for research purposes. A mere certificate describing the goods as consumables was not sufficient to alter their true character, particularly when the certifying authority had no expertise to classify the goods in that manner.

Conclusion: The tiles were not eligible for exemption and the finding in favour of the assessee was reversed.

---