Strict construction of exemption notifications denies relief for imported Cutch not named in the catechu entry.

Exemption notifications are construed strictly, and relief cannot be extended beyond the specific description chosen by the legislature or delegate. Although imported Cutch is a variety of catechu and an extract from the Acacia tree, the entry in Notification No. 76/86-C.E. covered only "Katha (Catechu)". Because the notification named that particular variety, the broader catechu classification was insufficient to claim exemption. The imported Cutch was therefore held ineligible for the notified benefit, and denial of exemption was upheld.

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Issues: Whether imported Cutch was entitled to exemption under Notification No. 76/86-C.E. at Sl. No. 6 covering "Katha (Catechu)".

Analysis: The notification extended exemption only to the specific variety described as "Katha (Catechu)". Although Cutch is also a variety of catechu and an extract from the Acacia tree, the exemption could not be extended beyond the particular entry chosen by the notification. The fact that the imported goods belonged to the broader catechu family was insufficient where the notification granted relief only to the named variety.

Conclusion: The imported Cutch was not eligible for exemption under the notification, and the denial of benefit was upheld.

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