Strict construction of exemption notifications bars MMRDA contract imports from customs duty relief absent express inclusion.

Customs duty exemption entries must be strictly construed, and a Metropolitan Development Authority could not be read into the phrase "road construction corporation" absent express wording. The notification separately referred to Metropolitan Development Authorities only after the 2012 amendment, indicating that the two expressions were distinct and that the later insertion expanded, rather than clarified, the benefit. Applying expressio unius est exclusio alterius, goods imported for a contract awarded by MMRDA did not qualify for exemption under Notification No. 21/2002-Cus. The importer was therefore not entitled to customs duty exemption, and the appeal was allowed while the exemption claim was rejected.

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Issues: Whether goods imported for a contract awarded by the Mumbai Metropolitan Regional Development Authority qualified for customs duty exemption under Notification No. 21/2002-Cus. Sr. No. 230 as a contract awarded by a road construction corporation under the control of the State Government.

Analysis: The exemption entry was construed strictly. The notification separately referred to a Metropolitan Development Authority only after the budget 2012 amendment, showing that prior to that amendment the two expressions were distinct. The authority issuing the notification also treated the later inclusion of Metropolitan Development Authorities as an extension of the benefit, which supported the view that the earlier entry did not cover such authorities. Applying the principle of expressio unius est exclusio alterius, a Metropolitan Development Authority could not be read into the expression road construction corporation.

Conclusion: The contract awarded by MMRDA did not fall within the exemption entry, and the importer was not entitled to customs duty exemption under the notification.

Final Conclusion: The appeal was allowed and the exemption claim was rejected.

Ratio Decidendi: An exemption notification must be strictly construed, and a Metropolitan Development Authority cannot be treated as a road construction corporation unless the notification expressly so provides.

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