Exemption for paper-making machine parts upheld where evidence showed imported blades were meant for use in paper machinery.

Imported doctors blades were treated as component parts intended for use in paper-making machinery, and the exemption under Notification No. 156/86-Cus. was applied on that basis. The notification covered paper-making machinery and its component parts, and the evidence of end use, including product literature and technical material, outweighed the contrary description in the import invoice. On that reasoning, the blades qualified for concessional treatment and the Revenue's challenge failed.

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Issues: Whether imported doctors blades were eligible for exemption under Notification No. 156/86-Cus. as component parts of paper-making machinery.

Analysis: The notification covered paper-making machinery and component parts classifiable under the relevant tariff headings. The goods were undisputedly parts, and the record showed that they were meant for use in paper machinery, including felt rolls and calender rolls. The product literature and technical material supported their use in paper-making machinery, and the contrary description in the invoice did not displace the overall evidence of end use. The wide scope of the exemption notification therefore supported the claim for concessional treatment.

Conclusion: The imported doctors blades were held to be eligible for exemption under Notification No. 156/86-Cus., and the Revenue's appeal failed.

Ratio Decidendi: Where exemption is available to paper-making machinery and its component parts, imported parts shown by the evidence to be intended for use in paper-making machinery qualify for the exemption notwithstanding an adverse description in the import documents.

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