Strict construction of customs exemption notifications denies relief for rotor and shaft imports outside paper-making machinery.

Strict construction of exemption notifications under customs law requires imported goods to fall within the notified description before relief can be claimed. Rotor and shaft imports were described as usable for pulp cutting rather than as paper-making machinery or component parts of such machinery, so they did not qualify under Notification No. 93/85-Cus. The exemption was therefore unavailable, and the denial of refund was upheld.

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Issues: Whether imported rotor and shaft were entitled to exemption as paper-making machinery or component parts under Notification No. 93/85-Cus. dated 17-3-1985.

Analysis: The notification granted exemption only to paper-making machinery and component parts thereof. The imported articles were stated to be usable for pulp cutting and not for paper-making machinery. Since exemption notifications are to be construed strictly, the benefit could not be extended to goods not falling within the notified description.

Conclusion: The imported goods were not eligible for exemption under the notification and the denial of refund was upheld.

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