Exemption notification interpretation: contact rating limit applied to all load types, defeating eligibility where resistive rating exceeded the threshold.

An exemption entry requiring relays to have a contact rating up to 7 amperes was interpreted as applying to all forms of contact rating because the notification did not distinguish between inductive and resistive load. Since the admitted resistive rating of the goods exceeded 7 amperes, the goods did not satisfy the exemption condition. The benefit of Notification No. 21/2002-Cus., List 26, entry 12 was therefore unavailable, and the claim failed.

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Issues: Whether relays claiming exemption under Notification No. 21/2002-Cus., List 26, entry 12, qualified as goods with contact rating up to 7 amperes when the resistive load exceeded 7 amperes but the inductive load was below that limit.

Analysis: The entry in List 26 did not qualify the phrase "contact rating up to 7 amperes" by reference to either inductive load or resistive load. In the absence of such a distinction, the expression was read as covering all forms of contact rating. Since the admitted resistive rating of the goods exceeded 7 amperes, they could not satisfy the notification condition.

Conclusion: The benefit of the exemption notification was not available, and the claim failed.

Ratio Decidendi: Where an exemption entry prescribes a contact rating limit without distinguishing between inductive and resistive load, the limit applies to all such ratings, and satisfaction of only one load parameter does not establish eligibility.

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