Substantial compliance with customs exemption conditions allowed for piston assemblies imported for tractor engine manufacture.

Imported piston assemblies were held to satisfy the essential conditions of Notification No. 82-Cus. dated 6-8-1960 because certificates showed they were required for manufacture of diesel engines for agricultural tractors and were imported in ready-for-fitment form. The exemption was therefore allowed on the basis of substantial compliance with the notification and acceptance of the prescribed end use. The claim relating to countervailing duty was not examined at that stage.

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Issues: Whether the imported piston assemblies were entitled to exemption under Notification No. 82-Cus. dated 6-8-1960.

Analysis: The goods were supported by certificates showing that they were required for manufacture of diesel engines for agricultural tractors and that the components were imported in ready-for-fitment form. The relevant conditions of the notification were treated as substantially satisfied, and the intended end use of the goods was accepted.

Conclusion: The exemption under Notification No. 82-Cus. dated 6-8-1960 was allowed in respect of the piston assemblies.

Final Conclusion: The appeal succeeded on the customs exemption issue, while the claim relating to countervailing duty was not examined at that stage.

Ratio Decidendi: Where the evidence establishes that imported goods satisfy the essential conditions of an exemption notification and are meant for the prescribed end use, the exemption is allowable on substantial compliance.

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