Exemption notifications are limited by stated tariff headings; compressor parts failed basic duty relief but qualified for auxiliary duty relief.

Piston rings for refrigeration compressors classifiable under Heading 8414.30 were held outside the basic customs duty exemption in Notification No. 153/86 because the notification applied only to the tariff heading expressly specified, and that heading was not covered. By contrast, the same goods qualified for auxiliary duty exemption under Notification No. 313/86 because the relevant entry extended to parts under Heading 8414.90 and was not limited to any particular compressor type. The matter was therefore only partly in the revenue's favour: basic duty relief failed, while auxiliary duty relief was available.

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Issues: (i) Whether piston rings for refrigeration compressors classifiable under Heading 8414.30 were entitled to basic customs duty exemption under Notification No. 153/86. (ii) Whether the same goods were entitled to auxiliary duty exemption under Notification No. 313/86.

Issue (i): Whether piston rings for refrigeration compressors classifiable under Heading 8414.30 were entitled to basic customs duty exemption under Notification No. 153/86.

Analysis: The notification granted exemption only to the compressor description and tariff heading specified in its table. The relevant entry covered compressors of the type falling under the specified heading for goods other than those for use in air-conditioning equipment. Since the imported goods admittedly fell under Heading 8414.30 and that heading was not specified in the notification, the exemption could not be extended to them. The scope of the exemption was limited by the tariff heading expressly mentioned in the notification.

Conclusion: The goods were not entitled to basic customs duty exemption under Notification No. 153/86.

Issue (ii): Whether the same goods were entitled to auxiliary duty exemption under Notification No. 313/86.

Analysis: The auxiliary duty notification exempted goods specified in the table and classifiable under Chapter Heading 84, and the relevant entry covered Heading 8414.90, which refers to parts. The exemption was framed with reference to parts of air or other gas compressors and was not restricted to any particular type of compressor. On that basis, the imported parts fell within the scope of the auxiliary duty exemption.

Conclusion: The goods were entitled to auxiliary duty exemption under Notification No. 313/86.

Final Conclusion: The order was modified so that the claim for basic duty exemption failed, while the claim for auxiliary duty exemption succeeded, resulting in a partial allowance of the revenue appeal.

Ratio Decidendi: An exemption notification must be applied according to the tariff heading and description expressly specified in it, and where the notification limits relief to particular headings, goods falling outside those headings cannot claim the exemption.

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