Exemption for integrated system denied where the Line Testing Unit was treated as a technically independent article.

A Line Testing Unit was held not to qualify for exemption under Notification No. 73/90 because technical literature and system architecture showed it was an independent unit, not an integral part of the Rural Automatic Exchange. The earlier ratio on the same question was applied, and the exemption claim failed on the footing that a technically separate article does not inherit the exemption available to the exempted system.

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Issues: Whether the Line Testing Unit was entitled to the benefit of Notification No. 73/90 as part of the Rural Automatic Exchange.

Analysis: The Tribunal noted that the identical question had already been examined in an earlier decision, where the technical literature and system architecture showed that the Line Testing Unit was independent of the Rural Automatic Exchange and was not fitted as an integral part of that system. On that basis, the earlier ratio was applied to the present dispute.

Conclusion: The Line Testing Unit was not eligible for the exemption under Notification No. 73/90 and the Revenue's appeal succeeded.

Final Conclusion: The exemption claim failed because the item in question was treated as an independent unit and not as part of the exempted system.

Ratio Decidendi: An article or unit that is technically independent of an exempted system and not an integral part of it does not qualify for the system's exemption benefit.

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