Bearing assemblies are distinct from bearings, so a strict exemption notification cannot be extended by interpretation.

A bearing assembly was treated as distinct from a bearing for classification under Chapter Heading 84.82 of the Central Excise Tariff Act, while bearing housings and similar assemblies fall under Chapter Heading 84.83. The exemption under Notification No. 6/2000, being directed to bearings, was held inapplicable to bearing assemblies and had to be construed strictly. The text also states that a rectification application can be used only to correct a patent mistake apparent from the record and cannot be employed to reopen a concluded classification view. Revenue reliance on other decisions was found unpersuasive on these facts.

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Issues: Whether a bearing assembly is classifiable as a bearing under Chapter Heading 84.82 of the Central Excise Tariff Act, 1985 and whether it is entitled to exemption under Notification No. 6/2000.

Analysis: The application was styled as a rectification of mistake, but in substance it sought review of the earlier order and could be entertained only for a patent mistake apparent from the record. On merits, the goods were held to be bearing assemblies and not bearings. Chapter Heading 84.82 covers ball or roller bearings, while bearing housings and similar assemblies are separately dealt with under Chapter Heading 84.83. The reasoning accepted that bearings and bearing assemblies are distinct commodities and that the exemption notification, being directed to bearings, could not be extended to bearing assemblies. The notification was construed strictly, and the Revenue's reliance on other decisions was found inapposite.

Conclusion: The goods are not classifiable as bearings under Chapter Heading 84.82 for the purpose of the impugned exemption, and Notification No. 6/2000 does not apply to bearing assemblies.

Ratio Decidendi: A commodity expressly distinct from the goods covered by an exemption notification cannot be brought within the notification by expansive interpretation, and rectification of mistake cannot be used to reopen a concluded view on classification.

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