Strict construction of exemption notifications excludes ingots and scrap from goods clearly listed for aircraft manufacture.

Import exemption under Notification No. 211/77-Cus., as amended, was confined to the specific goods listed in the annexed table for aircraft and helicopter manufacture. The notification covered finished forms such as coils, strips, sheets, rods, bars, extrusions, wires, tubes, castings, stampings and forgings, but not raw materials like ingots, pig iron or steel scrap. "Alloys" was read as qualifying the enumerated products rather than creating a separate residual class, and ingots were treated as distinct from castings. Applying strict construction, the goods not clearly covered by the notification could not be brought within its scope.

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Issues: Whether the imported raw materials, including steel ingots and similar items, were entitled to exemption under Notification No. 211/77-Cus. as amended by Notification No. 233/77-Cus., on the footing that they fell within the expressions used in the table annexed to the notification, particularly "alloys" and "castings".

Analysis: The notification granted exemption only to the specific goods enumerated in the annexed table for use in the manufacture of aircraft and helicopters. The listed items under serial No. 1 covered coils, strips, sheets, rods, bars, extrusions, wires and tubes of ferrous and non-ferrous metals and alloys, while serial No. II covered castings, stampings and forgings. The imported goods were described as ingots, pig iron, steel scrap and similar raw materials, which were neither the finished forms named in serial No. 1 nor goods of the same class as castings, stampings or forgings. The expression "alloys" was read as qualifying the listed products and not as an independent residual category. Ingots were held to be a separate commodity and not equivalent to castings, which denote cast goods having a distinct identity. An exemption notification of this kind had to be construed strictly and could not be extended to goods not specifically covered by its language.

Conclusion: The imported goods were not covered by the exemption notification and the claim for exemption failed.

Final Conclusion: The exemption was denied, and the appeals were dismissed as the disputed imports did not fall within the specified goods described in the notification.

Ratio Decidendi: An exemption notification must be construed strictly, and goods not specifically and clearly covered by the enumerated descriptions in the notification cannot be brought within its scope by expansive interpretation.

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