Customs exemption for bulk drugs requires strict compliance with notification conditions; later amendment did not create retrospective benefit.

Customs duty exemption for imported bulk drugs depended on strict compliance with the notification's mandatory conditions, including execution of a bond and maintenance and production of accounts showing use in manufacture for the specified purpose. Bulk drugs and raw materials were not covered by Chapter 99, which applied to life-saving drugs and medicines in ready-to-use form, so intended use in manufacture did not by itself secure exemption. The later amending notification did not operate retrospectively to validate a non-compliant claim or extend the benefit to the imports in question, and the exemption claim failed.

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Issues: Whether the imported bulk drugs were entitled to customs duty exemption under the relevant exemption notifications and Chapter 99, and whether the later amendment operated retrospectively to extend the benefit.

Analysis: The imported goods were bulk drugs and raw materials, not life-saving drugs or medicines in ready-to-use form. The exemption under the basic notification was subject to mandatory conditions, including execution of a bond and maintenance and production of accounts evidencing use in manufacture for the specified purpose. The amendments to the notification altered the conditions of exemption, but they did not validate a claim made without compliance with those conditions. Chapter 99 covered life-saving drugs and medicines, not the bulk drugs imported for manufacture. The later notification was not treated as conferring retrospective exemption on such bulk drugs.

Conclusion: The imported goods were not entitled to the claimed exemption, and the appeal failed.

Ratio Decidendi: Exemption under a customs notification is available only upon compliance with its mandatory conditions, and bulk drugs used as raw material do not acquire exemption merely because they are intended for manufacture of life-saving medicines or are later referred to in an amending notification.

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