Tariff classification and exemption wording required aluminium foils to be treated separately from sheets, defeating exemption benefit.

Imported aluminium foils were held not to qualify as "sheets" for exemption under the notification because the tariff scheme treated foils and sheets as distinct commercial and classification entries. The notification had to be construed consistently with that tariff differentiation, and the physical fact that foil is in sheet form did not override the separate use of the terms "sheet" and "foil" in the exemption text. On that interpretation, the exemption was unavailable to aluminium foils, and the denial of benefit was sustained.

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Issues: Whether imported aluminium foils could be treated as "sheets" for claiming exemption under the notification, and whether the tariff scheme required foil and sheet to be treated as distinct commodities for the purpose of the exemption.

Analysis: The exemption was available only where the notification specifically covered the goods in question. The tariff structure treated aluminium foils and sheets as separate items under different headings, showing that foil was a distinct commercial and tariff entity. The meaning to be given to the notification had to align with the tariff classification, and the fact that a foil is physically in sheet form did not make it a sheet for exemption purposes. The notification also used the expressions "sheet" and "foil" separately, indicating deliberate differentiation by the framers.

Conclusion: The imported aluminium foils were not entitled to exemption as sheets, and the denial of the notification benefit was upheld against the assessee.

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