Judgment

S.B. SINHA, J.-

The appellant before us is an undertaking wholly owned and controlled by the Central Government. It obtained the services of M/s SEDCO Forex Int. Drilling Inc. for exploration of oil and gas onshore and offshore. A contract was awarded by it to a company known as M/s SEDCO Forex Int. Drilling Inc. specialising in finding out the possibility of oil or gas by carrying out seismic surveys. The information gathered by reason of such survey was recorded in 3-D seismic tapes.

2. A question arose as to whether the same would attract the exemptions from payment of customs duty in terms of the entries contained in SL. Nos. 182,184 and 231 of the notification dated 28-2-1999.

3. For the aforementioned purpose, indisputably, an essentiality certificate was required to be issued by the Directorate General of Hydrocarbons. Prerequisite for grant of such certificate was also a valid petroleum exploration licence.

4. The licence granted by the Central Government in favour of the appellant in that behalf was initially valid up to 14-11-1997. The appellant applied for renewal thereof on 7-10-1997. An application for grant of essentiality certificate was filed on 5-4-1999. The