Strict construction of exemption notifications bars relief for unlisted autopasters imported with web printing machinery.

An exemption notification for a web printing machine was construed strictly: benefit was confined to the goods expressly listed in the notification's Table. Although the imported autopasters were classified under the same heading as the main machine, the notification covered the offset machine only and did not mention autopasters, parts, accessories, or auxiliary equipment. On that reading, the imported item fell outside the notified coverage and the exemption was unavailable.

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Issues: Whether autopasters imported for a web printing machine were entitled to exemption under Notification No. 114/80-Customs.

Analysis: The imported goods were already classified under the same heading as the main machine, so the dispute turned on exemption coverage. The notification extended benefit only to the goods specified in its Table. The Table covered the offset machine but did not mention autopasters, and the entry for the main machine did not include parts, accessories, or auxiliary equipment. As the notification did not specifically cover the imported item, exemption could not be granted.

Conclusion: The claim for exemption was rejected and the benefit of the notification was held to be unavailable to the autopasters.

Final Conclusion: The appeal failed because the notification was confined to the goods expressly listed in it and did not extend to the imported autopasters.

Ratio Decidendi: An exemption notification must be applied only to the goods expressly covered by its terms, and benefit cannot be extended to unlisted parts or accessories by implication.

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