Exemption notification scope for Winchester Disk Drive cannot extend to disk drives with controllers that alter the goods' character.

An exemption notification confined to Winchester Disk Drive did not extend to imported disk drives fitted with a controller. The controller performed an independent interfacing function in data transfer between the storage medium and the CPU, altering the character of the goods so they no longer answered the notification description. A certificate referring to magnetic disk could not enlarge the exemption to cover disk drives with controller. The benefit of Notification No. 281/84-Cus. was therefore correctly denied, and the Revenue's challenge to grant of the exemption succeeded.

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Issues: Whether disk drives imported with a controller fell within the exemption for Winchester Disk Drive under Notification No. 281/84-Cus.

Analysis: The description in the exemption notification was confined to Winchester Disk Drive. The imported goods were not simple disk drives but disk drives fitted with a controller, and the controller performed an independent interfacing function in the transfer of data between the storage medium and the CPU. On that basis, the addition of the controller altered the character of the goods so that they no longer answered the notification description. A certificate referring to magnetic disk could not extend the exemption to disk drives with controller.

Conclusion: The imported goods were not covered by the exemption and the benefit of Notification No. 281/84-Cus. was correctly denied; the appeal succeeded in favour of Revenue.

Final Conclusion: The exemption was held inapplicable to disk drives with controller, and the Revenue's challenge to the grant of benefit was accepted.

Ratio Decidendi: An exemption notification limited to a specified goods description cannot be extended to goods whose essential character is altered by an added controller performing an independent function.

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