Strict interpretation of exemption notifications bars tariff rules from narrowing benefits on imported parts of ball bearings.

Exemption notifications must be construed strictly on their plain terms, and tariff classification rules cannot be used to enlarge or restrict their scope. Imported goods were found to be parts of ball bearings, not complete ball bearings, so the benefit of Notification No. 146/86 could not be denied by invoking interpretative Rule 2(a) of the Customs Tariff. Section Notes, Chapter Notes, and classification rules applicable to tariff headings were held inapplicable to the interpretation of the notification. The stated effect was that the importers remained entitled to the exemption available to parts of ball bearings.

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Issues: Whether interpretative Rule 2(a) of the Customs Tariff could be invoked to construe Notification No. 146/86 and deny the benefit of the notification to imported parts of ball bearings.

Analysis: The dispute turned on the construction of an exemption notification and not on tariff classification alone. The goods imported were found to be merely parts of ball bearings and not complete ball bearings. It was held that exemption notifications must be interpreted strictly according to their plain language, and that Section Notes, Chapter Notes, or interpretative rules meant for tariff classification cannot be used to extend or modify the scope of the notification.

Conclusion: Interpretative Rule 2(a) could not be applied to the notification, and the appellants were entitled to the benefit applicable to parts of ball bearings.

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