Harmonious construction of DFIA import declarations: "resultant product" refers to exported goods, not the imported inputs.

An exemption notification under the DFIA scheme that incorporates the Handbook of Procedure must be read harmoniously with that procedure, so the declaration requirement cannot be applied in isolation. The reference to the "resultant product" was construed as the goods manufactured using the imported inputs, not the imported inputs themselves. On that reading, the exporter's shipping bill declaration was required to address the exported goods produced from the duty-free inputs, preserving the scheme's correlation between imports and exports and avoiding an impracticable result.

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Issues: Whether, under Notification No. 40/2006-Customs dated 01.05.2006 read with paragraph 4.55.3 of the Handbook of Procedure (Vol. I) of the Foreign Trade Policy 2004-09, the exporter was required to declare the technical characteristics, quality and specifications of the imported inputs in the shipping bill where those inputs were perfumes, essential oils and aromatic chemicals.

Analysis: The declaration requirement in the exemption notification had to be read harmoniously with the linked procedure under the Handbook of Procedure. The reference to the "resultant product" in the notification was construed as referring to the goods produced using the imported inputs under the DFIA scheme, not to the inputs themselves. Reading the provisions otherwise would defeat the scheme's object and make correlation between duty-free imports and exported goods impracticable. The earlier tribunal decisions did not control the issue because they did not turn on this construction of the notification and the Handbook together.

Conclusion: The declaration requirement applied to the goods manufactured using the imported inputs, and the Revenue's interpretation was correct. The question was answered in favour of the Revenue and against the assessee.

Final Conclusion: The appeal succeeded on the core interpretation issue, and the Tribunal's order was set aside with the matter remitted for decision on the remaining issues in accordance with law.

Ratio Decidendi: Where an exemption notification expressly incorporates the procedure in the Handbook of Procedure, both instruments must be read harmoniously, and a declaration condition tied to the "resultant product" is to be understood with reference to the exported goods made from the imported inputs rather than to the inputs themselves.

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