Strict construction of exemption notifications excludes detachable accessory parts from concessional duty when they do not serve the specified component.

Exemption notifications must be construed strictly, and concessional duty under Serial No. 2(ii) of Notification No. 33/88-Cus. was confined to parts of an alternator or generator. Parts belonging to a detachable vacuum pump, which functioned separately for braking and did not assist the alternator's operation, were not covered merely because the pump was mounted with the alternator unit. The common bearings and oil seals had already received the benefit, but the remaining imported parts were treated as components of the vacuum pump, so the principal concession claim failed. The alternative brake assembly claim was left for fresh examination.

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Issues: Whether parts imported for an alternator with detachable vacuum pump were entitled to concessional duty under Serial No. 2(ii) of Notification No. 33/88-Cus. as parts of alternator/generator.

Analysis: The imported goods related to a unit in which the alternator could function independently and the vacuum pump served a separate braking function. The literature and sample examination showed that the vacuum pump was a detachable component driven by the alternator shaft and did not assist the functioning of the alternator. Exemption notifications were required to be construed strictly, and the benefit under Serial No. 2(ii) was confined to auto electricals, namely alternator/generator. The common bearings and oil seals had already been granted the notification benefit, but the remaining parts were for the vacuum pump and not for the alternator itself.

Conclusion: The claim to concessional duty under Serial No. 2(ii) failed and was rightly rejected.

Final Conclusion: The appeal succeeded only to the limited extent that the alternative claim relating to brake assembly required fresh examination, while the principal claim under alternator/generator remained disallowed.

Ratio Decidendi: Where an exemption notification grants benefit to a specified component, the benefit cannot be extended to parts of a detachable and separately functioning accessory merely because it is mounted with that component.

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