Plain language of exemption notification covered independently imported sound recorders before amendment, preserving concessional customs duty.

An exemption notification must be construed according to its plain language, and a restrictive condition cannot be implied where the text separately names sound recorders. On that reading, independently imported sound recorders were covered by Notification No. 93/86-Cus. during the pre-amendment period and remained eligible for concessional customs duty. The later amendment narrowing the scope applied prospectively only and did not affect the earlier imports. The tariff classification under Heading 85.20 did not by itself exclude the goods from the benefit.

---

---

Issues: Whether independently imported sound recorders were covered by Notification No. 93/86-Cus., as amended, so as to qualify for concessional customs duty for the relevant period.

Analysis: The notification, as it stood before amendment, granted concessional duty to cinematographic projectors, sound recorders and combinations of those articles. The text of the notification did not justify reading the word "cinematographic" before sound recorders or sound reproducers. The subsequent amendment narrowed the scope for the future, but for the earlier period the exemption operated on the items separately. On the tariff scheme also, sound recorders falling under Heading 85.20 were not excluded from the benefit merely because they were not cinematographic apparatus.

Conclusion: The independent sound recorders were covered by the unamended notification for the relevant period and the refund claim was rightly allowed; the Revenue's challenge failed.

Final Conclusion: The exemption notification was construed to extend concessional duty to independently imported sound recorders during the pre-amendment period, and the Revenue's appeal was rejected.

Ratio Decidendi: An exemption notification must be construed according to its plain language, and where the notification separately names sound recorders, a restrictive condition not expressed in the text cannot be implied; a subsequent narrowing amendment operates prospectively.

---