Concessional duty notification held applicable despite incidental zinc admixture in copper alloy sheets and circles.

The concessional duty under Notification No. 119/66, as amended, was interpreted not to require that copper and copper alloy sheets and circles be manufactured solely from the specified inputs. The key question was whether an incidental admixture of zinc displaced the exemption, and the reasoning rejected that view because the notification did not use limiting words such as "only", "exclusively" or "entirely". On that construction, the presence of zinc did not by itself defeat entitlement to the concessional rate of duty, and the goods remained eligible for the benefit.

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Issues: Whether the appellants were entitled to the concessional rate of duty under Notification No. 119/66, as amended, on copper and copper alloy sheets and circles manufactured with admixture of zinc.

Analysis: The dispute turned on the construction of the exemption notification and whether the addition of zinc, which was not one of the specified materials, disentitled the goods to the concession. The order notes that an earlier appellate decision on the same notification had already held that the exemption was not confined to goods manufactured exclusively or entirely out of the specified inputs. That view had also been accepted in review, with the reasoning that the notification did not contain words such as "only", "exclusively" or "entirely" so as to exclude incidental admixture of other metals. On that basis, the presence of zinc did not, by itself, defeat the concession.

Conclusion: The appellants remained entitled to the concessional rate of duty notwithstanding the admixture of zinc.

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