Exemption for parts of power driven pumps depends on express notification wording, not tariff notes or broad interpretation.

Mechanical seals used as components of power driven pumps were not covered by Notification No. 155/86-C.E. because the exemption entry for power driven pumps did not expressly include parts. The tariff classification under Heading 84.13 was accepted, but that did not expand the scope of the exemption. The text of the notification controlled, and the fact that other entries specifically referred to parts showed that parts were included only where the Government said so in clear terms. Section notes and general rules of interpretation could not enlarge the exemption beyond its express wording.

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Issues: Whether mechanical seals, being components of power driven pumps, were entitled to exemption under Notification No. 155/86-C.E. as parts of power driven pumps.

Analysis: The dispute concerned eligibility for exemption, not the classification of the product, which was accepted as falling under Heading 84.13. The notification granted concession to the goods specifically described in the table, and the entry for power driven pumps did not mention component parts. In contrast, the notification expressly referred to parts in other entries, showing that where the Government intended to extend the benefit to parts, it did so in clear terms. The rule of interpretation and the section note in the tariff schedule could not enlarge the scope of an exemption notification beyond its express wording.

Conclusion: Mechanical seals, as parts of power driven pumps, were not covered by the exemption and the appeal failed.

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