Exemption for aircraft parts supplied to research institutions upheld under Notification No. 10/1997-CE as engineering goods.

Parts of aircraft supplied to specified research institutions were treated as eligible for exemption under Notification No. 10/1997-CE, because the notification extended to scientific and technical instruments, apparatus, equipment, accessories, spare parts, consumables, software and prototypes supplied subject to certification and usage conditions. A Board clarification also indicated that engineering goods could fall within the notification if those conditions were satisfied. On that reading, a narrow construction of the exemption was rejected, and the aircraft parts were held to fall within the notification. The appellant was therefore entitled to the exemption.

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Issues: Whether parts of aircraft supplied to specified research institutions were eligible for exemption under Notification No. 10/1997-CE.

Analysis: The exemption notification covered scientific and technical instruments, apparatus, equipment, accessories, spare parts, consumables, computer software and prototypes supplied to specified research institutions subject to the prescribed certification and usage conditions. A Board clarification stated that engineering goods also fall within the scope of the notification if the other conditions are fulfilled. The goods in question were parts of aircraft supplied to the specified institutions, and the same issue had been accepted for subsequent periods on the basis that such goods fall within the category of engineering goods. A narrow construction of the expression used in the notification was therefore not warranted.

Conclusion: The goods were covered by Notification No. 10/1997-CE and the appellant was entitled to the exemption.

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