Exemption for research equipment upheld where bus duct qualified as covered scientific and technical equipment under the notification.

M.V. bus duct supplied to a research institution was held to fall within Notification No. 10/97-C.E. because the phrase covering scientific and technical instruments, apparatus, equipment, accessories and spare parts was given a wide meaning that extended to electrical and mechanical equipment. Its classification as electrical instruments did not exclude coverage, and the certified research end-use with competent authority confirmation supported eligibility. Applying strict construction at the stage of coverage and liberal construction once eligibility was established, the exemption was held available and the departmental appeal failed.

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Issues: Whether M.V. bus duct supplied to a research institution was covered by Notification No. 10/97-C.E. as scientific and technical instruments, apparatus, equipment or accessories/spare parts thereof, so as to qualify for exemption.

Analysis: The expression used in the notification was held to be of wide import and capable of covering electrical as well as mechanical equipment. Mere classification of the goods as electrical instruments did not exclude them from the scope of the notification. The certified end-use and the competent authority's confirmation that the goods were required for research purposes were accepted. Applying the settled principle that an exemption notification is construed strictly at the stage of coverage but liberally once eligibility is established, the goods were found to fall within the notification.

Conclusion: The exemption under Notification No. 10/97-C.E. was available to the goods, and the departmental appeal failed.

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