Strict construction of exemption notifications excludes Bottom Press Pots from earlier customs concession unless expressly covered.

Bottom Press Pots were treated as distinct from Steel Pots in function, technical description and commercial understanding, with the former used in diamond polishing and the latter in diamond bruting. On that basis, the exemption under Notification No. 159/86-Cus. was not extended by implication to Bottom Press Pots. The later Notification No. 223/90-Cus., which specifically added Bottom Press Pots, indicated that they were not covered by the earlier notification and that the amendment was substantive rather than clarificatory. The governing principle stated is that exemption notifications must be strictly construed and cannot be enlarged beyond their express terms.

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Issues: Whether Bottom Press Pots were covered by Notification No. 159/86-Cus. dated 1-3-1986 so as to qualify for concessional customs duty.

Analysis: The items were found to be different in function, technical description, and commercial understanding. Steel Pots were used in diamond bruting, whereas Bottom Press Pots were used in diamond polishing. The later Notification No. 223/90-Cus. dated 26-7-1990 specifically extended the benefit to Bottom Press Pots, showing that they were not included in the earlier notification and that the later amendment was not merely clarificatory. Exemption notifications were required to be strictly construed, and the item not specifically covered could not be brought within the earlier notification by implication.

Conclusion: Bottom Press Pots were not eligible for concessional duty under Notification No. 159/86-Cus. dated 1-3-1986.

Final Conclusion: The appeal failed and the denial of concessional customs benefit was upheld.

Ratio Decidendi: An exemption notification must be strictly construed, and a later amendment adding a specific item indicates that the item was not covered by the earlier notification unless it is expressly included.

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