Exemption notifications must be read on their own terms; tariff notes cannot extend relief to saw blade segments.

An exemption notification must be construed on its own wording, and tariff classification rules cannot enlarge its scope unless the notification and tariff entry are truly coextensive. Chapter Note 2 of Chapter 82 provided only a classification formula and did not treat parts of saw blades as the complete goods covered by Tariff Heading 82.02. Because the segments were separately identifiable tradeable commodities and were not expressly covered by Notification No. 207/88-C.E., the exemption was unavailable. The later Notification No. 63/91 indicated a policy change and could not be treated as merely clarificatory or applied retrospectively.

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Issues: Whether segments being parts of saw blades, classified under Tariff Heading 82.02 by Chapter Note 2 of Chapter 82, were entitled to the benefit of Notification No. 207/88-C.E.

Analysis: The notification had to be construed according to its own words, and not by automatically importing tariff classification principles unless the notification and tariff expression were truly identical in scope. Chapter Note 2 of Chapter 82 only provided a classification formula for parts of base metal articles and did not equate parts with the complete goods covered by Tariff Heading 82.02. The segments were separately recognisable tradeable commodities and were not expressly included in the exemption notification. The subsequent Notification No. 63/91 dated 25-7-1991 reflected a change in exemption policy and could not be treated as merely clarificatory or given retrospective effect.

Conclusion: The benefit of Notification No. 207/88-C.E. was not available to the segments and the Revenue's appeal succeeded.

Final Conclusion: The exemption could not be extended to parts of saw blades on the basis of the tariff heading alone, and the impugned order granting the benefit was set aside.

Ratio Decidendi: An exemption notification must be interpreted on its own terms, and a tariff note or interpretative rule will not enlarge its scope to cover goods not expressly or necessarily included therein.

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