Strict construction of exemption notifications governs classification of imported tuner components under customs tariff interpretation rules.

Imported consignments containing components for mounting on bare printed circuit boards were treated as parts of TV tuners, not complete TV tuners, because an integrated circuit and other material components were absent. Exemption notifications must be construed strictly, and Rule 2(a) of the Customs Tariff interpretation rules cannot be used to enlarge the scope of a notification where the imported goods do not amount to the complete article covered by it. On the admitted facts, the missing components were sufficient to prevent classification as complete tuners for denying exemption benefit.

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Issues: Whether the goods imported were parts of TV tuners covered by the exemption notification, or complete TV tuners classifiable as such by applying Rule 2(a) of the Rules for the Interpretation of the Schedule to the Customs Tariff Act.

Analysis: The imported consignments were found to consist of components to be mounted on bare P.C.Bs., while the integrated circuit and certain other items were not imported. The dispute turned on whether the missing items were sufficient to prevent the goods from being treated as complete tuners. The Tribunal noted that exemption notifications must be interpreted strictly and that interpretative rules cannot be used to enlarge the scope of a notification. As the admitted facts showed that a material component of the tuner was not imported, the goods could not be treated as complete tuners for denying the notification benefit.

Conclusion: The import was held to be of parts of TV tuners and not complete TV tuners; the Revenue's objection failed.

Ratio Decidendi: Exemption notifications are to be construed strictly, and interpretative rules cannot be invoked to expand their scope where the imported goods do not constitute the complete article covered by the notification.

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