Strict construction of exemption notification excludes runners and risers from steel ingot treatment; promissory estoppel also failed.

Runners and risers arising in the manufacture of steel ingots were not treated as steel ingots for exemption purposes because they were merely leftover channels of molten metal, had no predetermined shape or size, and were not shown by commercial usage to answer the functional meaning of ingots. The exemption notification was construed strictly, so the broader tariff reference to steel ingots including steel melting scrap did not extend the notification's coverage. The claim based on promissory estoppel also failed for want of any enforceable assurance. The exemption was therefore unavailable, and the matter was remanded for de novo consideration on the remaining issues, including limitation.

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Issues: Whether runners and risers generated in the manufacture of steel ingots could be treated as steel ingots for the purpose of exemption under the relevant notification.

Analysis: The material on record showed that runners and risers were merely channels through which molten metal flowed into the ingot mould and were left-over material after the ingot was removed. They were not shown to be of any predetermined shape or size, nor was there evidence that trade or commercial usage treated them as ingots intended for a specific end use. Their nature and form were found to be essentially that of melting scrap. The exemption notification was therefore construed strictly, and the term "steel ingots" in the notification was not extended to cover runners and risers merely because the tariff entry referred to steel ingots including steel melting scrap. The plea based on promissory estoppel was also rejected as no enforceable assurance was shown.

Conclusion: Runners and risers were held not to qualify as steel ingots, and the exemption was not available to them. The order allowing the exemption was set aside, while the matter was remanded for de novo consideration on the remaining issues, including limitation.

Ratio Decidendi: An exemption notification must be interpreted according to its own terms, and a commodity not answering the commercial and functional meaning of the exempted product cannot be brought within the exemption merely because it arises in the same manufacturing process or is mentioned in the tariff in a broader composite entry.

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