Exemption notification for edible-grade imports cannot be narrowed by adding an unstated end-use condition.

Imported refined oils and candelilla wax were treated as eligible for exemption under Notification No. 50/2017-Customs because the goods matched the specified tariff classification and were shown by FSSAI/NABL-approved test reports to be of edible grade. The notification was read as requiring only those stated conditions, and no additional end-use restriction could be implied from the supplementary note or departmental circular. On that basis, denial of exemption on the ground of intended cosmetic or pharmaceutical use was held unsustainable, and the duty benefit was upheld.

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Issues: Whether the imported refined oils and candelilla wax satisfied the requirements of Notification No. 50/2017-Customs dated 30.06.2017, particularly the condition of being of edible grade, and whether an additional end-use condition could be read into the exemption.

Analysis: The goods were classified under the relevant tariff entries and the representative samples were tested by an FSSAI/NABL approved laboratory, which certified them as conforming to edible grade. The notification required only the specified classification and that the goods be refined and edible grade; it did not prescribe any end-use requirement. A condition not found in the notification could not be imported by relying on the supplementary note or on the departmental circular. The laboratory reports and the surrounding record were sufficient to establish compliance with the notification.

Conclusion: The imported goods were eligible for the exemption under Notification No. 50/2017-Customs dated 30.06.2017, and denial of benefit on the basis of intended cosmetic or pharmaceutical use was unsustainable.

Final Conclusion: The order extending the customs duty exemption to the respondent importer was upheld and the Revenue's challenge failed.

Ratio Decidendi: Where an exemption notification prescribes only specified classification and edible grade, no additional end-use condition can be read into it, and duly certified test reports may establish fulfillment of the edible-grade requirement.

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