Per T.K. Jayaraman:

M/s. Dell Computer India Pvt. Ltd. (hereinafter referred to as 'the appellant'), a 100% E.O.U. under the Software Technology Park Scheme of Government of India, are aggrieved over the fact that the impugned Order-in-Appeal denies the benefit of exemption Notification No. 52/2003-Cus. dated 31.3.2003 in respect of 'Master Key for Security Lock'.

2. Shri Prarmod Banthia, learned Chartered Accountant and Shri S. Madhavan, learned Advocate appeared on behalf of the appellants and Shri R.V. Ramakrishnappa, JDR appeared on behalf of the Revenue.

3. We have gone through the records and also heard the parties. The Commissioner (Appeals) in his order has clearly recorded that the imported item is mentioned in the Annexure to the Notification. Further, he has stated that the item cannot be said to be used in the manufacture for development of software, data entry and conversion, data processing, data analysis, etc. On this ground, the benefit of the exemption notification has been denied. We have gone through the technical literature. There are different types of security system. The following extract from the technical literature gives an idea about the function of the