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Issues: Whether the 12T payload single axle skeleton flat bed semi trailer was covered by Notification No. 10/97 dated 01.03.1997 as an apparatus, accessory, or spare part used with scientific and technical equipment.
Analysis: The notification extended the benefit not only to scientific and technical instruments, apparatus, and equipment, but also to accessories and spare parts of such goods. The certificate issued by the Department of Atomic Energy stated that the trailer was required for carrying scientific equipment for research purposes. On that basis, the trailer satisfied the description in the notification and could not be excluded merely because it was a vehicle-like item.
Conclusion: The issue was decided in favour of the assessee, and the exemption benefit was held admissible.
Ratio Decidendi: Where a notification grants exemption to scientific and technical instruments, apparatus, equipment, and their accessories or spare parts, an item certified as being used for carrying scientific equipment for research purposes falls within the notification if the stated conditions are otherwise satisfied.