Exemption for ISRO project goods denied where phenol formaldehyde resin was only a component, not a sub-system.

Phenol formaldehyde resin was not eligible for exemption under Notification No. 405/86-C.E., as amended by Notification No. 267/87-C.E., because the notifications covered only systems or sub-systems used in a launch vehicle or satellite project of ISRO. The certificate produced by the assessee described the goods as resin and showed that they were used to make a nozzle sub-system and as a binder in exhaust cores, which meant the goods were only raw material or a component part. A certificate could not override its own wording or transform resin into a sub-system for exemption purposes, so the claim for exemption failed.

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Issues: Whether the appellant's phenol formaldehyde resin was eligible for exemption under Notification No. 405/86-C.E., as amended by Notification No. 267/87-C.E., on the footing that it was a system or sub-system meant for use in a launch vehicle or satellite project of ISRO.

Analysis: The certificate produced by the appellant described the goods as resin and simultaneously indicated that they were used for making a nozzle sub-system and as a binder in exhaust cores. On a plain reading, the goods were not a system or sub-system by themselves but only a raw material or component used in the manufacture of a sub-system. The exemption granted by the notifications extended only to systems and sub-systems and did not cover raw materials or component parts. The certificate could not override its own contents or convert a resin into a sub-system for exemption purposes.

Conclusion: The resin was not eligible for exemption under the notifications, and the denial of benefit was .

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