Exemption for research-institute goods denied where manufacture was not shown to occur during training or research activities.

Goods manufactured in an R&D wing were held outside Notification No. 176/71-C.E. because the exemption applied only to excisable goods produced in a technical, educational or research institute during the course of imparting technical training or carrying out experiments or research. The record did not show that the respondent's unit itself produced the goods in such a training or research process; it only showed intended supply to another organisation. As the essential conditions of the notification were not met, the exemption was unavailable and the Revenue's appeal succeeded.

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Issues: Whether the goods manufactured in the R&D Wing of the respondent's factory and intended for supply to the Telecommunication Research Centre were entitled to exemption under Notification No. 176/71-C.E. dated 11-9-1971.

Analysis: The notification exempted excisable goods produced in a technical, educational or research institute during the course of imparting technical training of an academic or vocational nature or carrying out experiments or research. The goods in question were not shown to have been produced in the respondent's unit in the course of imparting such training or conducting such experiments or research in its own institute. The record only showed that the goods were intended for supply to another organisation. As the essential conditions of the notification were not satisfied, the exemption could not be extended.

Conclusion: The benefit of Notification No. 176/71-C.E. was not available to the goods in question, and the appeal of the Revenue succeeded.

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