Conditional exemption for research institutions cannot be denied merely because supplied equipment is general-purpose.

Conditional exemption under Notification No. 10/97 applies to goods supplied to a duly registered public funded research institution when the prescribed certificate and non-commercial research-use conditions are satisfied. The exemption cannot be denied merely because the items supplied, such as air-conditioning units, chillers, condensing units and walk-in cold rooms, are general-purpose equipment rather than instruments directly attached to scientific apparatus. Prior Tribunal decisions were followed on the same principle, and the exemption was held admissible.

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Issues: Whether air-conditioning units, condensing units, chillers and walk-in cold rooms supplied to a registered research institution were entitled to exemption under Notification No. 10/97 dated 01.03.1997.

Analysis: The notification granted exemption to specified goods supplied to a public funded research institution, subject to the institution being duly registered and certified for research use and non-commercial activity. The goods were claimed to have been supplied against the required certificate, and the only objection was that they were general-purpose items not directly attached to any scientific instrument. The Tribunal noted that the conditions of the notification had been fulfilled and that the issue stood covered by earlier Tribunal decisions holding that such exemption could not be denied when the prescribed conditions were satisfied.

Conclusion: The exemption was admissible and the Revenue's challenge failed.

Final Conclusion: The impugned orders allowing the exemption were sustained and the Revenue's appeal was dismissed.

Ratio Decidendi: Where the conditions of a conditional exemption notification for supplies to a registered research institution are satisfied, exemption cannot be denied merely because the goods are general-purpose equipment.

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