Concessional CST for scientific equipment: computers fell within a broad notification and were not limited by State schedule classification.

A notification issued under section 8(5) of the Central Sales Tax Act, 1956 must be construed on its own language, and a State sales tax schedule cannot be imported to narrow its scope where no such cross-reference exists. The broad expression covering scientific equipment and instruments, components and spare parts, and chemicals was therefore not confined to goods classified under entry 33 of the Bombay Sales Tax Act, 1959. On that ordinary meaning, computers used for data processing, instruction, and specialised scientific work fell within scientific equipment and instruments, so sales to educational institutions, hospitals, laboratories, and research institutions attracted the concessional rate.

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Issues: Whether computers sold to educational institutions, hospitals, laboratories, or research institutions qualified as scientific equipment and instruments under the notification issued under section 8(5) of the Central Sales Tax Act, 1956.

Analysis: The notification granted a concessional rate for inter-State sales of scientific equipment and instruments, components and spare parts, and chemicals to specified institutions on production of the prescribed certificate. The restrictive reading that confined the expression to goods falling under entry 33 of Part II of Schedule C to the Bombay Sales Tax Act, 1959 was rejected because the notification itself used broad language and did not incorporate the Schedule C classification. Entry 33 was relevant only for determining tax under the Bombay Act and could not control the scope of the Central notification. On the ordinary meaning of the expression, computers, being instruments used for data processing, instruction, and specialised scientific work, fell within scientific equipment and instruments.

Conclusion: Computers were covered by the notification and the assessee was entitled to the concessional rate of tax.

Ratio Decidendi: A notification under section 8(5) of the Central Sales Tax Act, 1956 must be construed according to its own clear language, and a goods classification under a State sales tax schedule cannot be imported to restrict the scope of scientific equipment and instruments where the notification does not so provide.

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