Strict construction of exemption notifications denies customs relief where the imported machine lacks the express qualifying feature.

A customs exemption notification was construed strictly according to its plain wording. The benefit was limited to a tool room precision optical coordinate jig boring machine, and the reference to numerical control only extended the concession to machines that already possessed the optical coordinate feature. Because the imported machine had numerical control but lacked the express optical coordinate requirement, it did not satisfy the qualifying description and was not entitled to exemption from customs duty. The Court refused to read additional words into the notification on the basis of technological superiority.

---

---

Issues: Whether the imported precision jig boring machine without an optical coordinate, but with numerical control, was entitled to the customs exemption for a tool room precision optical coordinate jig boring machine including numerical control.

Analysis: The exemption was confined to a machine fitted with an optical coordinate. The notification expressly extended the benefit even where such a machine also had numerical control, but it did not dispense with the requirement of the optical coordinate itself. The language of the notification was clear and admitted of no wider construction, and the Court declined to read words into it on the footing that numerical control was technologically superior.

Conclusion: The exemption did not apply to the imported machine, and the claim for customs duty relief failed.

Ratio Decidendi: An exemption notification must be construed according to its plain language, and the benefit cannot be extended to goods that do not satisfy the express qualifying description.

---