Customs exemption for crude palm oil turns on the notification's own terms, not food-law acid-value limits.

Crude palm oil imported under Heading 1511 was treated as eligible for exemption under Notification No. 21/2002-Customs where the notification required crude palm oil with acid value of 4 or more and specified carotenoid levels for refining use. The analysis states that the notification must be read on its own terms, and the acid-value ceiling from food-adulteration law could not be imported into it because the notification did not prescribe a limit of 10. As the goods were declared for refining and not for immediate human consumption, detention of the consignment and the proposed show-cause action were considered unsustainable.

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Issues: Whether crude palm oil imported under Heading 1511, having acid value of more than 10, was entitled to exemption under Notification No. 21/2002-Customs, and whether detention of the goods and issuance of show cause notice were justified.

Analysis: The exemption notification specifically covered crude palm oil falling under Heading 1511 having acid value of 4 or more and total carotenoid within the prescribed range for manufacture of refined oil or allied products. The Court held that the notification had to be construed on its own language and its scope could not be curtailed by importing the acid-value limit from the Prevention of Food Adulteration regime, since the notification itself did not impose a ceiling of 10. The goods were declared as crude palm oil for refining, not as food for immediate human consumption, and the Revenue had itself conceded that the case was not one of prohibited import. On that basis, detention of the consignment and the proposed action on the footing that the goods were ineligible for exemption were found unsustainable.

Conclusion: The importer was held entitled to the customs exemption, and the detention of the goods and related proceedings were held unjustified.

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