Textual interpretation of exemption notifications prevails, and extra-textual limits cannot deny exemption to covered goods.

Imported capital goods specifically covered by the tariff entries in Notification No. 25/2002-Cus remained eligible for exemption because the notification itself contained no restriction confining relief to IT or electronic industries. The text of the notification controlled its scope, and neither the heading nor the budget speech could be used to add a limitation not expressed in the notification. As the same issue had already been decided in the importer's favour for an earlier period, the later demand on the same reasoning was unsustainable. The recovery order was therefore set aside and the exemption claim succeeded.

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Issues: Whether the imported capital goods were eligible for exemption under Notification No. 25/2002-Cus, as amended, despite the department's stand that the notification was confined to IT/Electronic industries.

Analysis: The goods imported were specifically covered by the relevant serial numbers in the notification's table. The notification itself did not impose any condition limiting the exemption only to IT industries. The heading of the notification, or the budget speech, could not be used to read into the notification a restriction not found in its text. Since the same issue had already been decided in the appellant's favour for an earlier period, the subsequent demand based on the same reasoning could not survive.

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

Final Conclusion: The impugned recovery order was set aside and the appeal succeeded.

Ratio Decidendi: An exemption notification must be applied according to its text, and a restriction not expressly provided in the notification cannot be introduced from its heading or external materials; goods specifically covered in the notification remain eligible for exemption.

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