Customs exemption for life-saving equipment may carry a valid end-use safeguard to prevent misuse of the notification.

A revisional authority may attach a reasonable end-use condition when allowing customs exemption for life-saving equipment and their components under Notification No. 182-Cus./76, 2 August 1976. The condition requiring the importer to show that the components were not interchangeable with other electronic equipment and were usable only for D.C. Defibrillators was treated as a safeguard to keep the exemption within its intended scope and prevent diversion to other uses. The added restriction was therefore regarded as consistent with the notification's purpose, and the writ petition failed.

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Issues: Whether the revisional authority was competent to impose a condition requiring the importer to establish that the components were not interchangeable and were usable only for the manufacture of D.C. Defibrillators under Notification No. 182-Cus./76 dated 2-8-1976.

Analysis: The notification exempted life-saving equipment and their components and accessories generally used in hospitals from customs duty. The revisional authority had accepted the importer's basic claim for exemption, but added a safeguard requiring documentary proof that the imported items were not capable of use in other electronic equipment and were meant only for the notified medical equipment. The condition was treated as a measure to ensure that the exemption operated within its intended scope and was not diverted to other uses. Such a safeguard was held not to dilute or frustrate the spirit of the exemption notification.

Conclusion: The condition imposed by the revisional authority was valid and the writ petition failed.

Final Conclusion: The exemption under the customs notification was upheld in substance, but the added restriction was sustained as a lawful control on end use, leaving the petitioner without relief.

Ratio Decidendi: A revisional authority granting exemption in substance may impose a reasonable condition to ensure that imported goods are used only for the notified purpose and the exemption notification is not misapplied.

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