Strict construction of exemption notifications denies separate camera exemption when item is not expressly covered.

A separately imported colour camera intended for use with a surgical operating microscope was held not to qualify for exemption under Notification No. 144/88 because the notification covered only the equipment and the items expressly listed in its table. The note emphasises that exemption notifications must be applied strictly according to the description of the goods, and a component imported as a separate item cannot claim exemption merely because it may be used with otherwise exempt equipment. On that basis, the camera was treated as outside the notification and the assessee's claim failed.

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Issues: Whether a separately imported colour camera intended for use with a surgical operating microscope was entitled to exemption under Notification No. 144/88 as a part or accessory of the specified equipment.

Analysis: The exemption under Notification No. 144/88 was confined to the equipment and accessories or spare parts specifically enumerated in the table. At serial no. 35, the notification mentioned only "Surgical Operating Microscope Manual" and did not expressly include its parts or accessories. The camera was imported as a separate item and was not presented as an inbuilt component of the microscope. Since exemption notifications are applied to the goods as described and specified, a component imported separately cannot claim exemption merely because it may be used with exempted equipment.

Conclusion: The camera did not qualify for exemption and the decision was against the assessee.

Final Conclusion: The appeal failed because the imported camera was not a specified exempt item under the notification.

Ratio Decidendi: An exemption notification must be applied to goods only when they are specifically covered by its description, and a separately imported component is not exempt merely because it may be used with exempted equipment.

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