SUBHASH PHOTOGRAPHICS vs UNION OF INDIA

The Supreme Court examined the definition of 'industrial plant' under the Customs Tariff Act, 1975, specifically in relation to Chapter 98, which provides concessional duty rates. The Court held that the Project Import Regulations, 1986, which excluded photographic machinery from the definition of 'industrial plant', were valid and did not exceed the delegated legislative power under Section 157 of the Customs Act, 1962. The Court affirmed that the regulations were consistent with the statute and did not amount to excessive delegation of Parliament's legislative function.