Strict construction of exemption notifications excludes artificial teeth from relief meant for artificial limbs and rehabilitation aids.

Artificial teeth were treated as falling under the relevant tariff heading, but exemption under the notifications for artificial limbs and rehabilitation aids for the handicapped was denied because such exemptions must be construed strictly and apply only where the goods plainly fall within the notification wording. On the ordinary meaning of "limb," the term covers an arm, leg or similar appendage, not teeth. The loss of teeth was also held not to constitute handicap for this notification. Accordingly, artificial teeth were not covered by the exemption and no exemption was available.

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Issues: Whether artificial teeth are covered by the exemption for artificial limbs and rehabilitation aids for the handicapped under Notification No. 164/86-C.E. dated 01.03.1986, read with Notification No. 71/86-C.E. dated 10.02.1986.

Analysis: The product was accepted as artificial teeth falling under the relevant tariff heading, but the claim to exemption depended on whether they could be treated as artificial limbs or rehabilitation aids for the handicapped. The Court applied the settled rule that exemption notifications must be construed strictly and that a taxpayer can receive the benefit only when the goods fall plainly within the words of the notification. On the ordinary meaning of the expressions, a limb denotes an arm, leg, or similar jointed appendage, whereas teeth are not equivalent to limbs. The Court also held that loss of teeth does not make a person handicapped for the purpose of the notification.

Conclusion: Artificial teeth are not covered by the exemption notification, and the appellant is not entitled to exemption.

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