Exemption for shipyard goods requires direct and integral use in manufacture or repair, not merely ancillary operational support.

An exemption under Notification No. 431/86-C.E. was confined to goods manufactured in a shipyard and intended for direct use in the manufacture or repair of specified vessels and platforms. A caisson gate used to isolate a dry dock from sea water was held ineligible because, although it facilitated shipyard operations and created a dry working area, it was only ancillary to the work environment and not shown to be an integral part of the actual manufacturing or repair process. The notification was not construed broadly as covering articles merely connected with shipyard activity, since it did not use the wider phrase "in relation to manufacture". The exemption claim was therefore rejected.

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Issues: Whether caisson gate manufactured in a shipyard and used to isolate the dry dock from sea water was entitled to exemption under Notification No. 431/86-C.E. as goods intended for use in the manufacture or repair of specified vessels and platforms.

Analysis: The exemption applied only to goods manufactured in a shipyard and intended for use in the manufacture or repair of the specified goods. The expression used in the notification had to be read in its context and could not be expanded to cover every article facilitating shipyard operations. The caisson gate performed a structural function by creating a dry working area and preventing flooding. That use may have been connected with the shipyard activity, but it was not shown to be integrally connected with the actual process of manufacture or repair of the notified goods. The notification did not use the broader phrase "in relation to manufacture", and therefore a wider construction was not warranted.

Conclusion: The caisson gate did not qualify for exemption under the notification and the claim for relief was rejected.

Final Conclusion: The appeal failed because the item's function was only ancillary to shipyard operations and not a direct, integral part of the manufacture or repair of the notified goods.

Ratio Decidendi: An exemption notification limited to goods intended for use in the manufacture or repair of specified products covers only articles directly and integrally involved in the manufacturing or repair process, and not items that merely facilitate the work environment.

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