Concessional customs notification interpreted by plain language and context; Revenue's challenge failed, and benefit applied to imports.

On a plain reading of Notification No. 11/97-Cus. dated 1-3-1997 and its related entries, the SC found that the differing use of qualifying words in one entry and their absence in another showed that the concessional benefit was not intended to be narrowed in the way argued by the Revenue. Reading the notification in comparative context, the Court found no infirmity in the Tribunal's interpretation of its scope and applicability. The challenge therefore failed, and the notification was held to apply in favour of the respondent's imports.

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Issues: Whether Notification No. 11/97-Cus. dated 1-3-1997 excluded the respondent's imports from the concessional benefit on a proper reading of the relevant entries.

Analysis: The entries in the notification were examined on their plain language and in comparative context. The presence of qualifying words in one entry and their absence in the other indicated that the benefit was not meant to be curtailed in the manner suggested by the Revenue. No infirmity was found in the Tribunal's view on the scope and applicability of the notification.

Conclusion: The challenge failed and the notification was held applicable in favour of the respondent.

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