Exemption for vehicle-related parts and accessories was confined to internal combustion engines linked to motor vehicles, tractors and trailers.

Notification No. 75/86-C.E., as amended, exempted only specified parts and accessories of motor vehicles, tractors and trailers; the proviso had to be read with the opening exemption so that "the said goods" in condition (i) referred back to those vehicle-related items. The requirement that the goods be intended for use as original equipment parts in the manufacture of internal combustion engines under Chapter 84 was a limiting condition, not an expansion of the exemption. It therefore did not extend to all Chapter 84 internal combustion engines, including marine engines or stationary power-generating engines.

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Issues: Whether Notification No. 75/86-C.E., as amended, exempted only parts and accessories intended for use in internal combustion engines forming part of motor vehicles, tractors and trailers, or whether it extended to all internal combustion engines falling under Chapter 84.

Analysis: The opening part of the notification exempts specified parts and accessories of motor vehicles, tractors and trailers falling under the listed chapters, and the table identifies the covered goods. The proviso must be read with that opening part, so the expression "the said goods" in condition (i) refers back to those specified parts and accessories. On that reading, the requirement that the goods be intended for use as original equipment parts in the manufacture of internal combustion engines falling under Chapter 84 is a restricted condition tied to the exempted vehicle-related goods. It does not enlarge the exemption to all internal combustion engines, including marine engines or stationary power-generating engines.

Conclusion: The exemption was confined to internal combustion engines forming part of motor vehicles, tractors and trailers, and the broader claim for all Chapter 84 internal combustion engines was not accepted.

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