Plain meaning of "exported in bond" includes excise bond exports under the Customs Act, rejecting a narrower reading.

The expression "goods exported in bond" in the proviso to Section 20 of the Customs Act, 1962 was construed according to its plain and unqualified language to include exports under an excise bond as well as under a customs bond. The Court held that a locally manufactured article exported on bond could fall within the proviso, and that hardship, discrimination, or comparative duty burden could not justify narrowing clear statutory wording. The contrary view previously taken by the Madras HC was found inconsistent with the text and overruled, leaving the customs duty demand undisturbed.

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Issues: Whether the expression "goods exported in bond" in the proviso to Section 20 of the Customs Act, 1962 includes goods exported under an excise bond as well as goods exported under a customs bond.

Analysis: The proviso to Section 20, as it stood during the relevant period, referred to goods exported in bond and expressly dealt with payment consequences where excise duty had not been paid on indigenous materials or on the goods themselves. The statutory language was clear and unqualified. A locally manufactured article exported on bond could be exported under an excise bond, and the absence of restrictive words showed that the Legislature did not intend to confine the expression to a customs bond alone. The interpretation previously adopted by the Madras High Court was found inconsistent with the text of the section and was overruled. Questions of hardship, discrimination, or comparative duty burden were held not to justify departure from the statutory wording.

Conclusion: The expression "goods exported in bond" in Section 20 includes goods exported under an excise bond. The appellant's goods were covered by the proviso, and the contrary view was rejected.

Final Conclusion: The appeal failed, and the customs duty demand as upheld below remained undisturbed.

Ratio Decidendi: Where the language of a taxing provision is clear and unqualified, it must be given its plain meaning, and the expression "exported in bond" in Section 20 of the Customs Act, 1962 was construed to include export under an excise bond as well as a customs bond.

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