Strict construction of exemption notifications excludes company-owned replacement goods from "private personal property" customs relief.

Exemption notifications must be construed strictly on their clear language, and the words "private personal property" were given their ordinary meaning as property belonging to an individual in a private capacity. On that construction, goods owned by a company did not fall within the exemption, because a company, though a legal person, is not an individual's private personal property. The replacement tube therefore did not qualify for customs duty exemption under Notification No. 80/70, and the claim was rejected.

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Issues: Whether the expression "private personal property" in Notification No. 80/70 covered replacement goods imported by a public limited company, so as to grant exemption from customs duty.

Analysis: The expression "private personal property" was construed according to its ordinary and common meaning, since the notification did not define the words. On that construction, "private" and "personal" denoted property belonging to an individual in a private capacity. The principle that exemption notifications must be construed strictly, and that no intendment can be imported to extend the exemption beyond the clear language used, was applied. A company, though a legal person, was held not to answer the description of an individual's private personal property for this notification.

Conclusion: The replacement tube did not qualify for exemption under Notification No. 80/70, and the claim was rejected against the assessee.

Final Conclusion: The customs exemption was confined to replacement of goods that were the private personal property of an individual importer, and not of a company.

Ratio Decidendi: Exemption notifications are to be construed strictly on their clear language, and where the notification confines benefit to an individual's private personal property, the exemption cannot be extended to goods belonging to a company.

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