Strict construction of exemption notifications excludes modified phenolic resin blends from concessional duty under named resin descriptions.

A product described as a blend of estergum and modified phenolic resin, or rosin modified phenolic resin, was held not to fall within the specific description of phenol-formaldehyde resin in Notifications No. 190/82-C.E. and 241/82-C.E. The notifications were construed strictly because they used an express product description rather than the broader wording found in an earlier exemption notification, so the benefit did not extend to modified phenolic resins or blended resins. On the record, the product did not answer the notified description, and concessional duty was unavailable. The appeal therefore failed.

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Issues: Whether the product manufactured by the assessee was a phenol-formaldehyde resin eligible for concessional duty under Notification No. 190/82-C.E. and Notification No. 241/82-C.E.

Analysis: The product was described in the material on record as a blend of estergum and modified phenolic resin, or rosin modified phenolic resin. The notifications granted exemption only to phenol-formaldehyde resins and did not contain the broader definition found in Notification No. 122/71-C.E. The expression used in the later notifications was treated as a specific one, not a generic one, and therefore did not extend to modified phenolic resins or blends with other artificial or synthetic resins. On the record available, the product did not answer the notified description.

Conclusion: The product was not entitled to the concessional exemption under Notification No. 190/82-C.E. and Notification No. 241/82-C.E., and the appeal failed.

Ratio Decidendi: An exemption notification using a specific product description must be strictly construed, and a modified or blended resin does not qualify where the notification covers only the expressly named resin.

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