Evidence is essential to deny exemption: goods were not proved to be air-conditioning parts, so notification benefit remained available.

Goods were not shown to be parts of air-conditioning machinery, because the Revenue offered only a bare assertion and produced no description or supporting evidence. In the absence of material establishing that factual claim, denial of the benefit under Notification No. 175/86-C.E. could not be sustained. The classification accepted by the lower authority therefore remained undisturbed, and the respondents retained the notification benefit.

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Issues: Whether the goods manufactured by the respondents were liable to be treated as parts of air-conditioning machinery so as to deny the benefit of Notification No. 175/86-C.E.

Analysis: The Revenue's challenge rested only on a bare assertion that the goods constituted parts of an air-conditioning machinery. No description of the goods and no supporting evidence was produced to establish that factual claim. In the absence of material to show that the items were parts of air-conditioning machinery, the claim for denial of the notification benefit could not be accepted.

Conclusion: The issue was decided against the Revenue and in favour of the respondents; the goods were not shown to be disqualified from the benefit of Notification No. 175/86-C.E.

Final Conclusion: The appeal failed for want of supporting evidence and the classification and notification benefit granted by the lower authority remained undisturbed.

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