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Issues: Whether an increase in output achieved by upgrading an existing unit amounts to "substantial expansion" for the purpose of benefit under Heading 84.66.
Analysis: The governing test for "substantial expansion" is not merely an increase in production or capacity of the unit. The expression contemplates an addition comparable to setting up a new unit. Mere modernisation, revamping, or upgrading of an existing unit to secure higher output does not satisfy that requirement.
Conclusion: The claim for registration of the import contract under Heading 84.66 was rightly ? no, rejected; the issue is answered against the appellant and in favour of the Revenue.
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