Apex sporting body certificate can satisfy exemption conditions for imported goods where no separate end-use proof is prescribed.

An exemption under Notification No. 21/2002-Cus was available where the imported goods were certified by the apex sporting body as required for use in a national or international championship or competition. The AIFF certificate, issued as the apex body for football, satisfied the notification's condition because the text did not require any separate end-use certificate or additional proof beyond that certification. Strict construction could not be used to add a requirement not expressed in the notification. On that reading, the exemption applied and denial of the benefit was unsustainable.

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Issues: Whether the importer was entitled to exemption under Notification No. 21/2002-Cus dated 01/03/2002 on the strength of the AIFF certificate and the condition requiring the goods to be used in a national or international championship or competition.

Analysis: The notification required certification by the apex body in relation to the concerned sport that the requisites were required to be used in a national or international championship or competition to be held in India or abroad. The AIFF, being the apex body for football, issued the certificate, and the notification did not prescribe a separate end-use certificate or any additional condition beyond that certification. The certificate was therefore sufficient to satisfy the notification, and the reliance on strict construction did not alter the plain scope of the exemption in the facts of the case.

Conclusion: The exemption was admissible and the denial of benefit was unsustainable.

Ratio Decidendi: Where an exemption notification requires certification by the apex sporting body that the imported goods are required for use in a national or international championship or competition, the apex body certificate satisfies the prescribed condition and no further end-use certificate can be insisted upon unless the notification expressly so provides.

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