Exemption for medical probes upheld where ultrasound scanners met the notified description despite added scanning features.

Medical probes imported for manufacture of ultrasound scanners qualified for exemption under Notification No. 16/2000-Cus. because they were used in equipment satisfying the notified essential description and end-use. The presence of additional B-scan and M-scan facilities in the scanners did not defeat the exemption, as the notification was not to be read more narrowly than its language and did not expressly exclude such additional features. The principle applied is that exemption benefit remains available where the goods meet the core notified requirement, unless the notification specifically says otherwise. The denial of exemption was therefore unsustainable.

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Issues: Whether medical probes imported for manufacture of ultrasound scanners were entitled to exemption under Notification No. 16/2000-Cus. despite the scanners also having B-scan and M-scan facilities in addition to A-scan.

Analysis: The notification covered ultrasonic equipment of the notified type and parts required for the manufacture of medical equipment. The imported probes were used in the manufacture of ultrasound scanners that admittedly had A-scan capability. The mere presence of additional B-scan and M-scan facilities did not justify denying the exemption when the essential notified requirement was satisfied. The interpretation adopted was consistent with the applicable tariff advice and the principle that the notification should not be unduly restricted beyond its language.

Conclusion: The imported medical probes were eligible for exemption under Notification No. 16/2000-Cus., and the denial of benefit was unsustainable.

Ratio Decidendi: Where goods satisfy the essential description and end-use contemplated by an exemption notification, additional features of the equipment manufactured with those goods do not by themselves defeat the exemption unless the notification expressly so provides.

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