Exemption notification coverage for imported hangers could not be denied merely because the importer was not a job worker.

An exemption notification that used the term "importer" without defining it could not be read narrowly to exclude a non-job-worker where the goods were imported for execution of export orders. The notification expressly covered hangers and packing materials in its explanation, so the benefit could not be denied on the ground that the importer was not engaged in job work. The denial of exemption was therefore unsustainable, and the goods remained eligible for the notification benefit.

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Issues: Whether hangers imported for execution of export orders were eligible for the benefit of Notification No. 81/95-Cus. dated 31-3-1995 even though the importer was not a job worker.

Analysis: The notification used the term "importer" without defining it, and no restriction could be read into that expression. The goods covered by the relevant explanation included hangers and packing materials. The benefit could not be denied merely because the importer was not carrying on job work, when the import was for execution of export orders and the notification had to be construed in the context of its own terms.

Conclusion: The goods were eligible for the notification benefit, and the denial of exemption was unsustainable.

Ratio Decidendi: Where an exemption notification does not define or restrict the expression "importer", that term cannot be narrowly read to exclude an exporter or manufacturer, and the notification must be applied to goods expressly covered by its explanation.

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