Strict construction of exemption notifications barred concessional duty for clock radio sets treated as composite products.

An exemption notification granting concessional duty to radios was held to apply only to goods expressly described in its wording, so it could not be extended to clock radio sets classified under Heading 85.27. The tariff entry covered a composite product combining a radio and a clock, but for exemption purposes the notification was construed strictly and did not treat that composite article as a radio. A prior decision was distinguished because it involved different notification language. The clock radio therefore did not qualify for the concessional duty benefit, and the issue was decided in favour of Revenue.

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Issues: Whether clock radio sets falling under Heading 85.27 of the Central Excise Tariff Act, 1985 were eligible for the concessional duty benefit under Notification No. 158/86-C.E. dated 1-3-1986.

Analysis: The exemption notification was confined to radios, including transistor sets, and did not extend to all goods classifiable under Heading 85.27. The tariff entry covered combinations of radio apparatus with a clock, but the notification used a narrower description and had to be construed strictly. A combination of radio with a clock was treated as a composite product for tariff purposes and not as a radio for the purpose of the exemption. The earlier decision relied upon by the appellant was distinguished because it concerned a different notification with different wording.

Conclusion: The clock radio did not qualify for the exemption under Notification No. 158/86-C.E.; the issue was decided against the assessee and in favour of Revenue.

Ratio Decidendi: An exemption notification granting concessional duty to radios must be strictly construed according to its express wording, and its scope cannot be extended to composite products not specifically covered by the notification.

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