Strict construction of exemption notifications: textile printing was not treated as part of the printing industry for customs exemption.

Exemption notifications must be construed strictly according to their express words, and the expression "printing industry" is understood in commercial parlance rather than by the mere technical process of printing. On that approach, textile printing forms part of the textile industry, not the printing industry, so rubber blankets imported for use in textile printing did not fall within Notification No. 169/77-Cus. The later notification widening coverage to "printing on any surface" confirms that the earlier exemption was narrower, and the exemption claim was rejected.

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Issues: Whether rubber blankets imported for use in textile printing fell within the expression "printing industry" in Notification No. 169/77-Cus. so as to qualify for exemption.

Analysis: The exemption under the notification was restricted to rubber blankets imported for use in the printing industry. The term "printing" may in a technical sense extend to printing on cloth, but the expression "printing industry" had to be understood in its commercial or common parlance sense, not by reference to the mere process employed. The Court distinguished between the general process of printing and the trade understanding of the industry in which that process is used. In commercial understanding, textile printing forms part of the textile industry and not the printing industry. The later notification expanding the scope to "printing on any surface" indicated that the earlier notification was narrower. Exemption notifications must be construed strictly on the words used.

Conclusion: The imported rubber blankets used in textile printing were not covered by Notification No. 169/77-Cus.; the Collector (Appeals) was wrong and the Assistant Collector's order was restored.

Final Conclusion: The appeal succeeded and the exemption claim was rejected on the ground that textile printing did not fall within the printing industry under the earlier notification.

Ratio Decidendi: An exemption notification must be construed strictly according to its express words, and in commercial parlance textile printing is part of the textile industry, not the printing industry, unless the notification clearly expands the scope.

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