Exemption notification interpretation favours the assessee for projection lenses used in cinematographic projectors.

Projection lenses imported for use in cinematographic projectors were treated as eligible for the concessional duty treatment under Notification No. 93/86-Cus. dated 17-2-1986. The analysis applied the principle that, where two interpretations of an exemption notification are reasonably possible, the construction favourable to the assessee must be adopted. Following that approach and the later Bombay High Court view, the notification was held applicable to the imported lenses, and the claim to benefit under the notification succeeded on that issue.

---

---

Issues: Whether the appellants were entitled to the benefit of Notification No. 93/86-Cus. dated 17-2-1986 in respect of projection lenses imported for use in cinematographic projectors.

Analysis: The imported product was projection lenses for use in cinematographic projectors. The notification prescribed the effective rate of duty for cinematographic projectors, and the decision in the later Bombay High Court judgment was followed. The rule applied was that where two interpretations are possible, the one favourable to the assessee must be adopted.

Conclusion: The appellants were entitled to the benefit of Notification No. 93/86-Cus. dated 17-2-1986 and the appeal succeeded on that issue.

---