Ambulance exemption turns on prescribed fitments only, not medical equipment; denial of exemption was unsustainable.

Ambulances supplied with the prescribed fitments, furniture and accessories were held to satisfy the exemption entry because the notification required only those specified fittings and did not require installation of medical equipment. The vehicles had been configured to remain usable only as ambulances and were supplied to the Government of Maharashtra, leaving no real scope for misuse. On that basis, denial of exemption and the consequential penalty were found unsustainable, and the impugned order was set aside.

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Issues: Whether ambulances supplied after fitment of the prescribed fitments, furniture and accessories were entitled to exemption under the relevant notification, and whether the absence of medical equipment justified denial of exemption and penalty.

Analysis: The vehicles were fitted so as to remain usable only as ambulances, and they had been supplied to the Government of Maharashtra, leaving no real scope for misuse. The notification required fitment of the accessories specified in the exemption entry; it did not require installation of medical equipment. The specialised fitting of medical equipment was outside the appellant's expertise and was not a stated condition of exemption. Since the required accessories had already been provided, the denial of exemption was not sustainable.

Conclusion: The exemption was admissible and the impugned order was set aside.

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