Independent exemption entries and binding prior tribunal rulings bar re-adjudication of customs duty exemption entitlement.

An exemption notification with independent serial entries must be applied according to the specific entry governing the goods, and entitlement cannot be denied by reading the entries as a single composite provision. A prior final Tribunal ruling in the assessee's own case had already held that the goods qualified for full exemption from special additional duty, including under the entry covering complete exemption from basic and additional customs duty. Because that unchallenged ruling was binding, the Revenue and lower authorities could not reopen or re-adjudicate the same issue. The contrary view was therefore unsustainable, and the assessee was entitled to consequential relief.

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Issues: Whether the imported goods were entitled to full exemption from special additional duty under Notification No. 56/98 by virtue of compliance with Notification No. 104/95-Cus., and whether the matter was already covered by the Tribunal's earlier final order in the assessee's own case.

Analysis: The Notification was read as a table of separate serial entries, each operating on its own terms. The earlier final order had already held that the goods qualified for full exemption from special additional duty under the relevant serial entry and, in any event, were also covered by the separate serial entry granting full exemption where basic customs duty and additional customs duty were fully exempt. The lower authorities failed to follow that binding conclusion and attempted to reopen an issue already decided. Once the Tribunal had conclusively ruled on the exemption, the Revenue could not re-adjudicate the same matter in the absence of any challenge to that order.

Conclusion: The assessee was entitled to full exemption from special additional duty, and the contrary view of the Commissioner was unsustainable.

Final Conclusion: The appeal succeeded and the assessee obtained the claimed exemption with consequential relief.

Ratio Decidendi: Where an exemption notification contains independent serial entries, entitlement must be tested under the applicable entry as it stands, and a final unchallenged Tribunal ruling on the same issue binds the authorities and bars re-adjudication of that issue.

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