Exemption notification interpretation: later customs notifications read in pari materia with earlier scheme, extending exemption to the goods.

The exemption notifications in issue were treated as substantially identical in substance to the earlier Notification No. 281/76-Cus., with the later form differing only in presentation from descriptive wording to a tabular format. Construing the later notifications in pari materia with the earlier one, the Court held that inclusion of parts of the goods covered by the principal entry brought the appellant's goods within the exemption scheme. The benefit already recognised under the earlier notification was therefore extended for the period when Notifications No. 153/86-Cus. and 208-Cus. were in force, and the appellant was entitled to the exemption.

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Issues: Whether the appellant was entitled to exemption under Notification No. 153/86-Cus. dated 1-3-1986 as amended by Notification No. 208-Cus. dated 13-3-1986.

Analysis: The relevant exemption notifications were found to be substantially the same in substance as the earlier Notification No. 281/76-Cus. and its amended form, the only material change being the shift from descriptive expression to tabular presentation. The relevant language of the later notifications was treated as in pari materia with the earlier notification, and the inclusion of parts of the goods covered by the principal entry brought the appellant's goods within the exemption scheme. The Court therefore held that the benefit already recognised under the earlier notification had to be made available for the period during which the later notifications were in force.

Conclusion: The appellant was entitled to the exemption under Notification No. 153/86-Cus. dated 1-3-1986 as amended by Notification No. 208-Cus. dated 13-3-1986.

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