Strict construction of exemption notification denies duty relief for paper used in making core pipes.

Paper used in the manufacture of core pipes was held not to fall within the exemption for paper and paper board used within the factory for further manufacture of paper or paper board. Core pipes were treated as a distinct article of paper, classifiable under Tariff Item 4818.19, and not as paper or paper board for purposes of the notification. The exemption was construed strictly, and reliance on the cited Supreme Court decision was rejected because it concerned a different notification and different facts. Duty was therefore payable on the paper used for core pipes.

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Issues: Whether paper used in the manufacture of core pipes was exempt from duty under Notification No. 62/82, as amended by Notification No. 48/83 and Notification No. 79/86.

Analysis: The exemption covered only paper and paper board used within the factory for further manufacture of paper or paper board. Core pipes were found to be a distinct article of paper classifiable under Tariff Item 4818.19 and not paper or paper board. The expression used in the notification was construed strictly, and the reliance on the cited Supreme Court decision was rejected as that case involved a different notification and different facts.

Conclusion: The paper used in the manufacture of core pipes was not covered by the exemption notification and duty was payable.

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