Exemption for I.V. cannula upheld on broad reading of "blood vessels" in the tariff entry.

I.V. cannula were treated as falling within the exemption for disposable and non-disposable cannula for aorta, vena cavae, similar veins and blood vessels, because the expression "blood vessels" was read independently and not confined by the earlier words in the entry. The Tribunal followed its prior rulings on the same exemption language and noted that the Revenue's challenge had earlier failed before the Supreme Court. On that interpretation, denial of exemption based only on departmental opinion was not sustainable, and the exemption applied to the cannula manufactured by the appellants.

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Issues: Whether I.V. cannula manufactured by the appellants fell within the exemption entry for "Disposable and non-disposable cannula for aorta, vena cavae and similar veins and blood vessels and cannula for intra-corporal spaces" and were therefore eligible for exemption from duty.

Analysis: The appeal turned on the proper scope of the exemption description. The Tribunal followed its earlier decisions, which had already held that the expression "blood vessels" is to be read independently and not restricted by the words referring to aorta, vena cavae and similar veins. It also noted that the earlier view had been upheld when the Revenue's challenge was dismissed by the Supreme Court. The denial of exemption based only on the departmental opinion was therefore not sustainable, and the same interpretation governed the present notification framework.

Conclusion: The appellants were held eligible for exemption on the I.V. cannula manufactured by them, and the demand and penalties were set aside.

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