Exemption notification interpreted disjunctively for research or test laboratories, allowing concessional duty on air-conditioners.

An exemption notification concerning air-conditioners for use in "research and test laboratories" was construed in light of its beneficial object. The expression was read disjunctively, so the concession did not require a laboratory to be both a research laboratory and a test laboratory. Either description was sufficient to satisfy the condition. On that construction, denial of concessional duty for the air-conditioner was not justified, and the article states that the air-conditioner was eligible for the concession.

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Issues: Whether the expression "research and test laboratories" in Notification No. 56/78-C.E. required a laboratory to be both a research laboratory and a test laboratory for the concession to apply, and whether the air-conditioner was eligible for concessional duty under the notification.

Analysis: The expression in the notification was read in the context of the object of the concession. The condition was not construed as requiring a laboratory to satisfy both descriptions cumulatively. A laboratory that was either a research laboratory or a test laboratory was sufficient. On that construction, the refusal to extend the concessional rate to the air-conditioner was not justified.

Conclusion: The concession was wrongly denied and the air-conditioner was held eligible for concessional duty under the notification.

Ratio Decidendi: Where an exemption notification is intended to grant a concession to a class of laboratories, the qualifying words may be read disjunctively to give effect to the beneficial object of the notification and avoid an unduly restrictive construction.

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