Tariff classification and customs exemption depend on recorded identity and strict proof of the notification's exact terms.

Imported Alsint two bore insulators were held classifiable as electrical insulators under Heading 8546.20 because the record described them as insulators and porcelain for laboratory use, and did not establish that they were parts of pyrometers under Heading 9025.90. The exemption claim under Notification No. 97/89-Cus. also failed because the appellants did not prove that the goods fell within the limited notified categories or were parts required for manufacture of the specified instruments. The article states that classification must follow the specific tariff description supported by the record, and exemption notifications must be strictly proved within their exact terms.

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Issues: (i) whether the imported Alsint two bore insulators were classifiable as parts of pyrometers under Heading 9025.90 or as electrical insulators under Heading 8546.20; and (ii) whether the goods were eligible for exemption under Notification No. 97/89-Cus.

Issue (i): Whether the imported Alsint two bore insulators were classifiable as parts of pyrometers under Heading 9025.90 or as electrical insulators under Heading 8546.20.

Analysis: The invoice and declaration described the goods as insulators and porcelain for laboratory use. The record did not establish that they were parts of pyrometers. Where the tariff specifically covers electrical insulators, the goods must be classified under that description on the basis of their recorded identity and description.

Conclusion: The classification under Heading 8546.20 was upheld and the claim for classification under Heading 9025.90 failed.

Issue (ii): Whether the goods were eligible for exemption under Notification No. 97/89-Cus.

Analysis: The notification covered specified instruments and their parts only for the limited categories mentioned in the table. The appellants did not establish that the imported goods were parts required for manufacture of the specified instruments or that they fell within the notified description. No material on record supported the exemption claim.

Conclusion: The benefit of Notification No. 97/89-Cus. was not available.

Final Conclusion: The importers failed on both classification and exemption, and the order of the revenue authorities was sustained.

Ratio Decidendi: Goods must be classified according to the specific tariff description supported by the record, and exemption notifications must be strictly proved to apply within their exact terms.

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