Exemption notification construction: concessional duty cannot be denied by importing an unexpressed route condition from another notification.

An exemption notification must be construed strictly on its own language, and a condition from a separate notification cannot be read into it unless expressly incorporated. The concessional rate under Notification No. 76/2003-Cus. remained available because that notification did not restrict the route of import or make its benefit contingent on compliance with the route requirement in Notification No. 63/94-Cus. (N.T.).

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Issues: Whether benefit of Notification No. 76/2003-Cus. dated 13-5-2003 could be denied merely because the goods were imported through a route not authorised under Notification No. 63/94-Cus. (N.T.) dated 21-11-94.

Analysis: The exemption notification was found to contain no condition restricting the route of import and no rider linking its benefit to compliance with the route requirement in the separate notification governing import route. Exemption notifications were to be construed strictly according to their own words, and words from another notification could not be imported to add a condition not expressed in the notification granting concessional duty.

Conclusion: The concessional rate of duty under Notification No. 76/2003-Cus. dated 13-5-2003 remained admissible notwithstanding violation of the route condition in Notification No. 63/94-Cus. (N.T.) dated 21-11-94.

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