Strict construction of exemption notifications barred customs relief for frozen embryos under a frozen semen exemption.

Customs duty exemption for frozen semen could not be extended to frozen embryos imported in liquid nitrogen because the notification used a specific term with a defined meaning. Semen was understood as the male fecundating fluid containing spermatozoa, while an embryo was a later developmental stage after fertilisation and therefore fundamentally different. Applying strict construction to exemption notifications, the benefit was confined to the clear language of the notification. Frozen embryos were held outside the exemption, and the Revenue's appeal succeeded.

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Issues: Whether frozen embryos imported in liquid nitrogen were entitled to exemption under the notification granting customs duty exemption to frozen semen.

Analysis: The notification granted exemption only to frozen semen. Semen was understood as the male fecundating fluid containing spermatozoa, whereas an embryo was a later developmental stage after fertilisation. The two were held to be fundamentally different and not interchangeable. As exemption notifications must be construed strictly, the benefit could not be extended beyond the clear language of the notification to cover frozen embryos.

Conclusion: Frozen embryos were not covered by the exemption notification for frozen semen and the Revenue's appeal succeeded.

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