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Issues: Whether the Project Imports Regulations, 1986 were invalid insofar as they defined "industrial plant" so as to exclude service establishments like photographic studios from project import benefit.
Analysis: The challenge was concluded by the binding Supreme Court decision which upheld the validity of the Project Imports Regulations, 1986. It was held that the expression "industrial plant" could validly be defined so as to exclude service establishments like photographic studios from the project import benefit. Since that decision squarely governed the controversy, no independent reconsideration of the validity challenge was called for.
Conclusion: The Regulations were held valid and the exclusion of photographic studios from project import benefit was upheld, against the assessee.