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    <title>1996 (9) TMI 390 - CEGAT, NEW DELHI</title>
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    <description>Hand tools such as pick axes, beaters, powrah/hoe/spade, shovels and crow-bars were treated as agricultural implements for exemption purposes because the controlling test was common and direct use in agricultural operations, not exclusive agricultural use. The fact that the goods were also capable of civil construction or other non-agricultural use did not defeat exemption where they were commonly used for agriculture and intimately connected with agricultural work. The exemption under Notification No. 55/75-C.E. therefore applied, subject only to the specific exclusions in the notification.</description>
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