Strict compliance with re-export time limits governs customs exemption; failure to seek extension defeats relief.

Exemption under Notification No. 158/1995-Cus. was available only where re-export of re-imported goods was completed within six months of re-importation, with a further extension of up to six months if granted by the Commissioner of Customs. Because the goods were re-exported after six months, and no extension had been sought or allowed, the time condition was not satisfied. The notification had to be construed strictly, and all prescribed conditions were required to be met. On that basis, the importer was held not entitled to the exemption, and the duty and interest demand was upheld.

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Issues: Whether the importer was entitled to exemption under Notification No. 158/1995-Cus. when the re-export of re-imported goods took place beyond six months from re-importation without any request for extension of time.

Analysis: The exemption notification permitted re-export within six months of re-importation, with a further extension of up to six months only if allowed by the Commissioner of Customs. The goods were re-exported within one year but beyond six months, and no permission for extension had been sought. Since the condition governing the time for re-export was not complied with, the exemption could not be availed. Exemption notifications are to be construed strictly, and all their conditions must be fulfilled.

Conclusion: The importer was not entitled to the exemption, and the demand of duty and interest was upheld.

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