Exemption for spectacle lenses denied where imported rough blanks required further processing before becoming the finished article.

Imported ophthalmic rough blanks were held not to qualify as "spectacle lenses" under the exemption notification because the notification used that description in plain, unambiguous terms. The interpretative rule for incomplete or unfinished articles could not override the specific wording of the exemption. As the goods still required grinding, polishing and curvature fixation before becoming spectacle lenses, they were treated as a different item for notification purposes, and the nil countervailing duty exemption was denied.

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Issues: Whether imported ophthalmic rough blanks were entitled to nil countervailing duty under Notification No. 234/82-C.E. as "spectacles, spectacle lenses and spectacle frames".

Analysis: The Notification used the specific description "spectacle lenses" without ambiguity. The rule governing incomplete or unfinished articles was held inapplicable for construing the Notification, because such interpretative aids cannot override the plain language of an exemption notification. The imported goods were only rough blanks and required further processes such as grinding, polishing and curvature fixation before they could become spectacle lenses. On that basis, the goods were treated as not the same item as spectacle lenses for the purpose of the exemption.

Conclusion: The imported ophthalmic rough blanks did not fall within Sl. No. 7 of the Notification and the exemption was not available.

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