Customs exemption for component parts extends to spare parts, and multiple notifications may apply absent express prohibition.

Where a customs notification grants concessional treatment to "component parts", spare parts are not excluded merely because they are described as spare parts, so the benefit of Notification No. 156/Cus. 86 was correctly allowed. Simultaneous benefit of more than one notification is also permissible where there is no express prohibition, and the attempted distinction between basic and auxiliary duty did not displace that principle, so Notification No. 69/Cus. 87 could be applied alongside the other exemption. The lower appellate authority's grant of both notification benefits was sustained and the Revenue's challenge failed.

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Issues: Whether spare parts could be treated as component parts for the benefit of Notification No. 156/Cus. 86, and whether the benefit of Notification No. 69/Cus. 87 could be taken simultaneously with another notification.

Issue (i): Whether spare parts could be treated as component parts for the benefit of Notification No. 156/Cus. 86.

Analysis: The relevant notification used the expression "component parts". The Tribunal relied on the Larger Bench ruling that spare parts are not excluded from that expression and that the concessional benefit cannot be denied merely because the goods are described as spare parts.

Conclusion: The benefit of Notification No. 156/Cus. 86 was rightly allowed.

Issue (ii): Whether the benefit of Notification No. 69/Cus. 87 could be taken simultaneously with another notification.

Analysis: The governing principle drawn from earlier Tribunal decisions was that simultaneous benefit of more than one notification is permissible where there is no express prohibition. The distinction suggested between basic duty and auxiliary duty was held insufficient to displace that principle.

Conclusion: The benefit of both notifications was correctly extended and the Revenue's challenge failed.

Final Conclusion: The order of the lower appellate authority granting the notification benefits was sustained, and the Revenue's appeal was rejected.

Ratio Decidendi: Where a notification speaks of component parts, spare parts are not excluded from its scope, and simultaneous benefit of multiple notifications cannot be denied in the absence of an express prohibition.

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