End-use based concessional assessment applies only to the quantity specifically covered by DGTD certification.

Concessional assessment under Notification No. 37/79 was available only to the extent the imported winding temperature indicators and oil temperature indicators were supported by end-use evidence and DGTD certification for manufacture of power transformers. The record contained an end-use affidavit, DGTD certificate and related documents, but the documentary support was quantity-limited. Reassessment was therefore accepted only for the certified quantity, namely 40 winding temperature indicators, while the balance claim was not accepted. The operative principle is that exemption or concession based on end-use documentation is confined strictly to the goods actually covered by the supporting certificate.

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Issues: Whether the imported winding temperature indicators and oil temperature indicators were entitled to concessional assessment under Notification No. 37/79 to the extent they were supported by end-use and DGTD certification.

Analysis: The goods were claimed as component parts of transformers and the concession under the notification was sought on the basis that they were required for manufacture of power transformers. The record showed an end-use affidavit, DGTD certificate, and other supporting documents. The departmental position accepted reassessment only for the quantity covered by the DGTD certificate, and the Bench found the documentary evidence sufficient for that limited extent.

Conclusion: The concession and re-assessment were allowed only for the goods covered by the DGTD certificate, namely 40 winding temperature indicators.

Final Conclusion: The appeal succeeded only to the limited extent of the certified quantity, with the remaining claim not accepted.

Ratio Decidendi: Where documentary evidence establishes that imported goods are specifically covered for end-use in manufacture and the supporting certificate is quantity-limited, concessional assessment may be granted only to the extent of the certified coverage.

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