Literal interpretation of exemption notifications upheld for imported digital cameras, with strict proof of all cumulative conditions.

An exemption notification that is clear and unambiguous must be construed literally, and the claimant must strictly establish that all stated conditions are cumulatively satisfied. Applying that construction to imported digital still image video cameras, the larger bench held that the goods fell within the notification parameters and were entitled to exemption from Basic Customs Duty.

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Issues: Whether the imported digital still image video cameras were entitled to exemption from Basic Customs Duty under the relevant customs notification as amended.

Analysis: The larger bench held that the exemption notification admitted no ambiguity on the relevant explanation and had to be read literally. It also held that the conditions in the explanation had to be cumulatively satisfied, and that the claimant of exemption bore the burden of establishing that the goods fell within the notification. On that construction, the imported cameras satisfied the notification parameters and were within the scope of the exemption.

Conclusion: The goods were eligible for exemption from Basic Customs Duty under the notification.

Ratio Decidendi: An exemption notification, when clear and unambiguous, is to be interpreted literally, and the claimant must establish strict satisfaction of its conditions; where the goods fall within those conditions, the exemption must be granted.

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