Home consumption clearance cannot later be converted into project import eligibility; timing of contract registration remains decisive.

Goods cleared on a home consumption bill of entry could not later be re-characterised as warehoused goods to obtain project import registration and concessional assessment. The customs framework treated home consumption and warehousing entries as distinct, and an exhibition exemption notification did not override the separate timing requirement that the contract be registered before clearance for project import benefit. Because registration was sought only after the goods had already been cleared, the statutory condition for concessional assessment was not met, and the exemption under Notification No. 116/79-Cus. did not confer entitlement to project import treatment.

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Issues: Whether goods imported for exhibition under Notification No. 116/79-Cus. and cleared on a home consumption bill of entry could later qualify for project import registration and concessional assessment under Heading 84.66 of the Customs Tariff Act, 1975.

Analysis: The governing customs framework distinguished between goods entered for home consumption and goods entered for warehousing. A bill of entry filed in the prescribed form for home consumption could not be re-characterised as a warehousing entry merely because the goods were imported for display at a fair and were covered by an exhibition exemption notification. The exemption notification and the project import registration scheme operated in different fields. Since the application for registration of the contract was made only after the goods had already been cleared against the home consumption bill of entry, the statutory precondition for project import assessment was not satisfied. The notification also did not displace the requirement that registration be obtained in time for project import benefit.

Conclusion: The appellants were not entitled to project import registration or to the benefit of Notification No. 116/79-Cus.; the claim failed and the revenue prevailed.

Final Conclusion: The decision held that exhibition goods cleared on a home consumption bill of entry could not subsequently be treated as eligible for project import concessions, and the exemption notification could not be used to override the timing requirement for contract registration.

Ratio Decidendi: Where the customs entry has already been made and cleared as a home consumption entry, subsequent application for project import registration does not satisfy the statutory condition for concessional assessment, and an exemption notification for exhibition goods does not by itself create entitlement to project import benefit.

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