Strict compliance with customs concession conditions required before clearance; unregistered import contract defeated the tariff benefit.

A concessional customs duty benefit under Heading 84.66 was available only if the import contract was registered with customs before clearance of the goods. The appellants ed that the contract had not been registered within that time. Because the statutory precondition was not met, the concession could not be granted and strict compliance with the prescribed conditions was required for availing the tariff benefit.

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Issues: Whether the appellants were entitled to the concessional rate of customs duty under Heading 84.66 of the Customs Tariff Act, 1975 despite the contract not having been registered with customs before clearance of the goods.

Analysis: The benefit under the heading was subject to a statutory condition that the import contract must be registered with customs prior to clearance. The appellants accepted that the contract had not been so registered. As the prescribed condition was not fulfilled, the concession could not be granted.

Conclusion: The appellants were not entitled to the concessional rate of duty under Heading 84.66, and the issue was decided against them.

Final Conclusion: The appeal failed because the statutory precondition for the customs concession was not satisfied.

Ratio Decidendi: A fiscal concession attached to a tariff heading can be availed only on strict compliance with the statutory conditions prescribed for that benefit.

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