Crude palm oil exemption interpretation clarifies "4 or more" acid value has no upper limit, preserving concessional benefit after reprocessing.

Interpretation of an exemption notification concerning imported crude palm oil turns on textual construction: the phrase indicating Acid Value "4 or more" has no upper limit, so an upper limit cannot be read into the notification, and denial of concessional benefit solely because the Acid Value exceeded 10 was not justified. A strict textual approach and burden of proof on the denying authority is endorsed, and reliance on an unrelated administrative circular is rejected as inapposite. Reprocessing of imports to meet edible standards and subsequent PHO clearance negates the ground for denial, resulting in allowance of relief where notification criteria are met by permissive reading.

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Issues: Whether crude palm oil consignments declared as "edible grade" are entitled to benefit under Notification No.21/2002-Cus. (Sl. No.30(II)(A)) where laboratory test reports show acid value greater than 10, given that the notification specifies "acid value of 4 or more" without an upper limit.

Analysis: Notification No.21/2002 as amended (Sl. No.30(II)(A)) grants exemption to crude palm oil of edible grade described as having an acid value of "4 or more" and specified carotenoid range; the text of the notification contains no express upper limit on acid value. Conflicting laboratory reports were placed before the authorities; some reports recorded acid values above 10 while others recorded lower values. The authorities also permitted reprocessing of the imported goods and clearance after Port Health Officer (PHO) certification. Relevant precedents interpreting the notification (including High Court and Supreme Court decisions) confirm that where the exemption notification unambiguously specifies "4 or more" an upper limit cannot be read into the notification, and that such exemptions must be given effect unless the notification itself is ambiguous. The Revenue's reliance on external standards or circulars imposing a maximum acid value does not alter the clear wording of the exemption entry in the notification.

Conclusion: The benefit of Notification No.21/2002-Cus. is available to the consignments declared as crude palm oil (edible grade) despite laboratory reports showing acid value above 10; the impugned orders denying the exemption are set aside and the appeals are allowed (in favour of the assessee).

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