Strict construction of exemption notifications denied relief for membrane elements treated as components, not water purification equipment.

Membrane elements imported for a filtration system were held not to qualify as water purification equipment under CTH 84212190 for exemption under Notification No. 6/2006-CE. The item was only a component of the system and did not itself purify water as equipment. Applying strict construction of exemption notifications, the burden remained on the assessee to prove that the goods squarely met the notification's description and conditions. As that burden was not discharged, the Revenue's classification under CTH 84219900 was accepted and the assessment and demand were sustained.

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Issues: Whether membrane elements imported by the assessee were classifiable as water purification equipment under CTH 84212190 and eligible for exemption under Notification No. 6/2006-CE dated 01.03.2006, or were classifiable under CTH 84219900 and liable to customs duty.

Analysis: The notification granted exemption to water purification equipment falling under the specified tariff entry and based on the stipulated technologies. The imported item was only a membrane element, which served as a component of the filtration system and did not itself purify water as equipment. Exemption notifications must be strictly construed, and the burden lies on the assessee to show that the goods fall within the terms of the exemption.

Conclusion: The imported membrane elements were not eligible for the exemption and the Revenue's classification was accepted.

Final Conclusion: The assessment and demand were sustained, and the appeal failed.

Ratio Decidendi: An exemption available to water purification equipment cannot be extended to a mere component unless the assessee proves that the goods themselves satisfy the notification's description and conditions.

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