Strict compliance with customs exemption conditions bars relief when ATA Carnet goods are not exported within the prescribed time.

Conditional customs exemption under Notification No. 157/90-Cus applied only if ATA Carnet goods were exported within six months of importation, with a further six-month extension available by the proper officer. The imported goods were not exported within either period, so the stipulated condition was not met. Because exemption notifications must be construed strictly and the claimant must prove full compliance with their terms, the duty exemption was unavailable. The Revenue's appeal accordingly succeeded.

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Issues: Whether the importer was entitled to customs duty exemption under Notification No. 157/90-Cus dated 28/03/1990, as amended, despite failure to export the goods within the prescribed period.

Analysis: The notification granted exemption only on satisfaction of the condition that goods imported under ATA Carnet be exported within six months from the date of importation, extendable by a further six months by the proper officer. The goods were imported on 16/12/2011, but were neither exported within the original period nor within the extended period up to 06/12/2012. Exemption notifications must be construed strictly in accordance with their express terms, and the claimant must clearly establish fulfilment of the stipulated conditions. Since the prescribed condition was not complied with, the exemption could not be claimed.

Conclusion: The importer was not entitled to the duty exemption, and the Revenue's appeal succeeded.

Ratio Decidendi: A conditional exemption under a customs notification is available only upon strict compliance with the prescribed terms, and failure to satisfy the export-within-time condition disentitles the claimant from the exemption.

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