Exemption for tempered glass denied because the notification covered only specified goods or parts consumed in their manufacture.

Notification No. 205/88-C.E. was construed narrowly: Sl. No. 18 applied only to parts consumed in the factory for manufacture of goods specified in Sl. Nos. 1 to 17, and the manufacturer was not producing any such specified goods. Sl. No. 1 covered flat plate solar collectors as complete goods, not a single component used in their manufacture. Tempered glass, being only one part of the collector, did not qualify for exemption under either entry, so the exemption claim failed.

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Issues: Whether tempered glass was eligible for exemption under Notification No. 205/88-C.E. dated 25-5-1988 either as a part covered by Sl. No. 18 or as goods falling under Sl. No. 1 as flat plate solar collectors.

Analysis: Sl. No. 18 applied only to parts consumed within the factory of production for manufacture of the specified goods under Sl. Nos. 1 to 17, and the assessee was not manufacturing any of those goods. Sl. No. 1 covered flat plate solar collectors themselves, whereas the item in dispute was only one component used in their manufacture and not a complete flat plate solar collector. The notification therefore did not extend to the tempered glass claimed by the assessee.

Conclusion: Tempered glass was not eligible for exemption under Notification No. 205/88-C.E. dated 25-5-1988, and the claim failed.

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