Strict construction of exemption notifications bars concessional customs benefit for toner cartridges not expressly covered.

Toner cartridges imported for laser printers were outside the concessional customs benefit framed for ink cartridges. The notification was construed strictly, so an exemption or concession could not be extended by implication to goods not expressly covered or intended to be covered. The subsequent amendment also applied only to ink cartridges, and its benefit operated prospectively from the date of issue unless made retrospective. On that basis, the claim to duty concession for toner cartridges failed.

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Issues: Whether toner cartridges imported for laser printers were covered by the concessional duty benefit meant for ink cartridges under the customs notifications.

Analysis: The import was of toner cartridges, while the concessional entry in the relevant notification applied to ink cartridges. The subsequent amendment notification also extended the benefit only to ink cartridges and not to toner cartridges. A notification conferring exemption or concession cannot be extended by presumption to goods not intended to be covered, and the benefit operates from the date of its issuance.

Conclusion: The toner cartridges were not entitled to the duty concession available to ink cartridges, and the claim of the appellant failed.

Ratio Decidendi: A fiscal exemption notification must be construed strictly, and its benefit cannot be extended by implication to goods not expressly or intendedly covered; a later notification operates prospectively unless expressly made retrospective.

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