Strict construction of exemption notifications bars concessional duty for goods not matching the specified description.

Concessional duty under Notification No. 23/98 was confined to insoles, midsoles and sheets thereof for use in the leather industry, and exemption notifications had to be applied strictly. The imported material was described as insole material sheets but was found to be in rolled form, so it did not answer the specific description in the notification. Expert opinions produced by the importer did not establish that the goods fell within the notified category. The claim for concessional duty therefore failed, and the goods were held not to be covered by Notification No. 23/98.

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Issues: Whether the imported goods, described as insole material sheets but found to be in rolled form, were eligible for concessional duty benefit under Notification No. 23/98 as goods for use in the leather industry, namely insoles, midsoles and sheets thereof.

Analysis: The exemption notification was confined to insoles, midsoles and sheets thereof, and the expression used indicated that only goods falling within that specified description could qualify. The imported material was found not to be insole or midsole sheets, but in rolled form, and the expert opinions relied upon by the importer did not establish entitlement to the notified concession.

Conclusion: The imported goods were not covered by Notification No. 23/98 and the claim for concessional duty failed.

Ratio Decidendi: An exemption notification granting concessional duty must be applied strictly, and goods not answering the specified description in the notification cannot be brought within its benefit.

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