Strict compliance for customs exemption failed where literature described goods as air-conditioners rather than qualifying heat pumps.

Exemption under Notification No. 30/88 depended on strict compliance with the notification and the importer's burden to prove that the imported items answered the description required for concessional duty. The manufacturer's literature described the goods as an air-conditioner and a heat pump type air conditioner, not as heat pumps within the meaning of the notification. On the concurrent factual findings, there was no basis to disturb the authorities' conclusion, and the claim for exemption was rejected.

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Issues: Whether the importer was entitled to exemption or concessional duty under Notification No. 30/88 dated 01.03.1988 in respect of the imported items described in the manufacturer's literature.

Analysis: The claim for exemption depended on the importer establishing strict compliance with the notification. The material before the authorities showed that the manufacturer's operational manual described the goods as an air-conditioner and as a heat pump type air conditioner, rather than as heat pumps in the sense required by the notification. The importer had the burden to prove eligibility for the exemption, and the Court found no reason to disturb the concurrent factual findings recorded below.

Conclusion: The importer failed to discharge the burden of proving entitlement to the exemption, and the claim under the notification was rejected.

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