Exemption notification interpretation supports prima facie coverage despite tariff restructuring, justifying waiver of pre-deposit and stay of recovery.

On a plain reading of the exemption notification, goods not falling within the express exclusion for margarine and similar edible preparations remained covered despite tariff restructuring and reclassification under a revised heading. The applicants therefore established a prima facie entitlement to exemption and were granted waiver of pre-deposit and stay of recovery pending disposal of the appeals.

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Issues: Whether the applicants had made out a prima facie case for exemption under the relevant notifications and were entitled to waiver of pre-deposit and stay of recovery.

Analysis: The goods were earlier covered under the tariff entry to which the exemption applied. After tariff restructuring, the goods were treated as classifiable under the revised heading, but the wording of the notification continued to extend the benefit to all goods other than margarine and similar edible preparations. On a plain reading, the goods in question did not fall within the excluded category. The applicants, therefore, established a prima facie entitlement to the exemption.

Conclusion: The applicants were entitled to waiver of pre-deposit and stay of recovery pending disposal of the appeals.

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