Printed books exemption extended to imported computer sheets where tariff classification and notification language were read consistently.

Imported running computer sheets in source code form were treated as printed books for customs exemption because Chapter Note 4(c) to Chapter 49 covered printed parts of books in assembled or separate sheets designed for binding. Where the exemption notification did not define "printed books" differently, its meaning was taken from the tariff schedule and the parent statute. Applying the same expression consistently, and finding no contrary intention in the notification, the goods were held eligible for exemption. The denial of auxiliary duty benefit was set aside and consequential relief was granted to the importer.

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Issues: Whether imported running computer sheets in source code form were classifiable as printed books for the purpose of exemption under Customs Notification No. 139/90 dated 20-3-1990.

Analysis: The goods were found to fall within Chapter Note 4(c) to Chapter 49, which covers printed parts of books in the form of assembled or separate sheets constituting the whole or part of a complete work and designed for binding. The term "printed books" in the notification was not separately defined, and its meaning was therefore to be gathered from the tariff schedule. Since the goods were treated as printed books for tariff classification, there was no reason to deny the same character for the exemption notification. The notification was not shown to indicate any contrary intention, and the expression used in it was held to bear the same meaning as in the parent enactment and schedule, supported by Section 20 of the General Clauses Act.

Conclusion: The imported goods were held eligible for exemption under the notification, and the denial of auxiliary duty benefit was set aside in favour of the assessee.

Final Conclusion: The appeal succeeded and the impugned customs order was reversed, granting the consequential relief claimed by the importer.

Ratio Decidendi: An expression used in an exemption notification issued under a statute ordinarily carries the same meaning as in the parent Act or tariff schedule, unless the notification shows a contrary intention.

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