Customs exemption for life-raft food rations upheld where functional context showed they formed part of survival equipment.

Food rations imported for Indian Navy life rafts were treated as part of the ship's survival equipment and as goods imported by an authorised person on behalf of the Government of India, so they satisfied Notification No. 150/94. The functional and commercial understanding of the goods, rather than a narrow dictionary meaning of fitment, governed classification, and the international safety convention on life-saving appliances supported that view. On that basis, exemption was available and confiscation under the Customs Act was unsustainable.

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Issues: Whether food rations imported for life rafts of Indian Navy ships were eligible for exemption under Notification No. 150/94, and whether confiscation under Section 111(d) of the Customs Act, 1962 was sustainable.

Analysis: The imported food rations were covered by the condition that the goods be imported by an authorised person on behalf of the Government of India, as evidenced by the certificate from the Controllerate of Procurement. The material on record showed that the rations were sealed in the life rafts and formed part of the survival equipment of the ship. The meaning to be adopted was the one understood by persons dealing with such goods in their commercial and operational context, not a narrow dictionary meaning of fitment. The international safety convention relating to life-saving appliances also supported the view that food rations are part of the required equipment of a life raft.

Conclusion: The imported goods were eligible for exemption under Notification No. 150/94, and confiscation under Section 111(d) of the Customs Act, 1962 was unsustainable.

Final Conclusion: The appeal succeeded, the confiscation order was set aside, and consequential relief followed.

Ratio Decidendi: Goods used as mandated equipment of a ship's life raft are to be classified and understood in their functional commercial context, and where the exemption conditions are satisfied, denial of exemption and consequent confiscation cannot be sustained.

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