Exemption notification for tyres cannot be enlarged to cover dual-use radial tyres; concessional duty claim fails.

Imported radial tyres designed for both on-road and off-road use were held outside the scope of the concessional countervailing duty exemption under Notification No. 20/84-C.E. because the notification covered only specified tyre categories and did not extend to tyres intended for multiple applications. Tariff Item 16 distinguished tyres for motor vehicles from tyres for vehicles or equipment designed for off-road use, and the exemption was treated as clear and unambiguous. Beneficial construction was held inapplicable to enlarge an exemption notification beyond its express terms, so the claim for concessional duty failed.

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Issues: Whether imported radial tyres designed for both on-road and off-road applications were entitled to concessional countervailing duty under Notification No. 20/84-C.E. dated 1-3-1984.

Analysis: Tariff Item 16 classifies tyres separately, including tyres for motor vehicles and tyres for vehicles or equipment designed for use off the road. The exemption notification grants concessional duty only to specified categories of tyres and does not extend to tyres designed for multiple uses. The imported tyres were described by the manufacturer as suitable for on/off road application, and the notification was held to be clear and unambiguous. The principle of beneficial construction was found inapplicable to an exemption notification, and no scope was found for extending the concession beyond its express terms.

Conclusion: The benefit of the notification was rightly denied and the claim for concessional countervailing duty failed.

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