Strict construction of exemption notification excludes steel sheets used as fabrication raw material from consumable goods treatment.

Imported steel sheets and plates used as raw materials for fabricating rocket motor hardware were not "consumable goods" under Notification No. 70/87-Cus. because they retained their identity after use and were not used up or wasted away in the process. Strict construction of exemption notifications required the goods to fall clearly within the covered category, and their aerospace application did not change their character. The exemption was therefore unavailable, and the issue was decided against the assessee.

---

---

Issues: Whether steel sheets/plates imported for fabrication of rocket motor hardware for a single-shot application qualified as "consumable goods" entitled to exemption under Notification No. 70/87-Cus. dated 1-3-1987.

Analysis: The exemption applied only to consumable goods and spare parts required for research. The imported steel sheets/plates retained their identity as sheets and plates even after use, and no new goods emerged from them. They were used as raw materials and specific components in fabrication of finished articles, not goods that were used up or wasted away in the process. Exemption notifications are to be construed strictly, and the aerospace use of the goods did not alter their character for the purpose of the notification.

Conclusion: The steel sheets/plates were not consumable goods within the meaning of the notification, and the exemption was not available. The finding was against the assessee and in favour of the Revenue.

---