Generic exemption entries must be read in ordinary commercial sense; steel pots used in diamond processing qualified for exemption.

Notification entries describing goods in generic terms must be read in their ordinary commercial sense, and an exemption cannot be narrowed by adding an end-use restriction that is not expressed. Applying that approach, the Tribunal treated "steel pots" as a broad description covering the imported bottom press pots and top pots used in diamond cutting and polishing, and preferred the manufacturer's catalogue as the more reliable description of the goods. The imports were therefore found to fall within Entry No. 67 of Notification No. 159/86-Cus., making the denial of exemption unsustainable.

---

---

Issues: Whether the imported steel pots, including bottom press pots and top pots, were covered by Entry No. 67 of Notification No. 159/86-Cus. and entitled to exemption.

Analysis: The entry used the expression "steel pots, steel counter pins" without adding words limiting the exemption by end-use. The manufacturer's catalogue was treated as a more reliable guide than a trader's catalogue, and it indicated that pots made of steel were used in diamond cutting and polishing in different forms. The description "steel pots" was therefore held to be a generic expression covering various kinds of steel pots used in the diamond industry. The Tribunal declined to confine the entry only to pots used for bruting or to read into the notification words that were not there. Applying the general understanding of the goods, the imports were found to satisfy the notification.

Conclusion: The imported goods were held eligible for exemption under Entry No. 67 of Notification No. 159/86-Cus., and the denial of benefit was unsustainable.

Ratio Decidendi: A notification entry describing goods in generic terms must be construed according to their ordinary commercial understanding, and where no restrictive end-use condition is expressed, the exemption cannot be narrowed by importing words into the notification.

---