$~17 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 27^th March, 2025 + CUSAA 71/2024 & CM APPL. 51080/2024 PRINCIPAL COMMISSIONER OF CUSTOMS .....Appellant Through: Mr. R. Ramachandran, Sr. SC with Mr.

Prateek Dhir, Adv. (M:9868211477)

versus M/SGO IP GLOBAL SERVICES PVT. LTD .....Respondent Through: Mr. A.K. Prasad and Ms. Surabhi Sinha, Advs.

CORAM:

JUSTICE PRATHIBA M. SINGH JUSTICE RAJNEESH KUMAR GUPTA Prathiba M. Singh, J. (Oral)

1. This hearing has been done through hybrid mode.

2. This is an appeal under Section 130G of the Customs Act, 1962 arising out of the Customs, Excise and Service Tax Appellate Tribunal (hereinafter “CESTAT”) impugned order dated 3^rd January, 2024.

3. The short issue that arises in the present petition is in respect of the interpretation of the word ‘and’ appearing in the clause (iv) of Serial No. 13 of Notification No. 11/2014-Customs dated 11^th July, 2014, i.e., “Multiple Input/ Multiple Output (MIMO) and Long Term Evolution (LTE) Products”. The CESTAT vide the impugned order has interpreted the said terms i.e., MIMO and LTE in conjunction and thereby, held that the subject goods would not be covered in the exclusion clause of the exemption not