Strict construction of customs exemptions: an accessory imported with a machine gets concessional duty only if expressly covered.

Exemption notifications granting concessional customs duty are strictly construed, and their benefit extends only to goods clearly covered by the stated description. An imported Electronic Pitch Tester Attachment was treated as an accessory to the main tester, but it was not expressly included in the notification's table for Chapter 90 goods. Its inability to function independently did not make it part of the exempt machine for duty purposes. The exemption therefore did not apply to the attachment, and the assessee's claim for concessional duty failed.

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Issues: Whether the concessional rate of customs duty under the exemption notification covered the imported Electronic Pitch Tester Attachment as an accessory imported with the main machine.

Analysis: The notification granted exemption only to the goods specifically described in the table and falling within Chapter 90, and the named article was the Gear Profile and Helix Tester. The attachment was found to be an accessory used with the tester and not expressly included in the notification. Exemption notifications are to be strictly construed, and in case of doubt the benefit does not extend by implication to items not clearly covered. The fact that the attachment could not function independently did not make it part of the machine for exemption purposes.

Conclusion: The attachment was not entitled to the concessional rate of customs duty, and the claim of the assessee failed.

Ratio Decidendi: An accessory imported with an exempted machine does not qualify for concessional duty unless the exemption notification expressly includes accessories within its coverage.

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