Clarificatory amendment to exemption notification on computers and CPUs was treated as retrospective for pre-deposit relief.

The amended exemption notification was read as clarificatory because it retained the original entry for "computers" and merely added an explanation stating that computers include CPUs. On a prima facie view, the explanation was treated as relating back to the original notification rather than introducing a new restriction or benefit. That interpretation supported interim relief, and full waiver of pre-deposit was granted on the basis that the amendment could operate retrospectively for the dispute at that stage.

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Issues: Whether the amended notification adding an explanation to include CPUs within the expression "computers" operated retrospectively so as to support waiver of pre-deposit.

Analysis: The original notification used the expression "computers" under the relevant tariff heading, and the later amendment did not replace that entry but only added an explanation to state that computers include CPUs. On a prima facie reading, the explanation was viewed as clarificatory of the main entry rather than creating a new restriction or benefit. Such an explanation was therefore treated as capable of relating back to the original notification for the purpose of interim relief.

Conclusion: The amendment was treated as having retrospective effect prima facie, and full waiver of pre-deposit was granted.

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