Strict construction of exemption entries excludes rectangular casseroles from concessional duty for specified glass tableware.

Rectangular casseroles were held outside Notification No. 67/88-C.E., because the concessional duty entry was confined to specified tableware of glass such as jugs, cups, plates, drinking glasses and bowls. Applying the common parlance test, the article was found not to fall within any named category, and the notification could not be extended to an unenumerated product merely because it broadly belonged to glassware. The analysis reaffirmed that exemption notifications must be construed strictly, with any ambiguity resolved against the claimant and in favour of the Revenue.

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Issues: Whether rectangular casseroles are eligible for concessional duty under Notification No. 67/88-C.E., dated 1-3-1988 as tableware of glass.

Analysis: The notification granted concessional duty only to specified items of tableware of glass, namely jugs, cups, plates, drinking glasses and bowls. The product was described as a rectangular casserole, and the decisive question was not whether it could be regarded generally as tableware, but whether it fell within any of the specific categories named in the notification. Applying the common parlance test and the technical material produced, the product was found not to be akin to the enumerated items. Exemption notifications are to be construed strictly, and any ambiguity must be resolved against the claimant and in favour of the Revenue.

Conclusion: Rectangular casseroles are not covered by Notification No. 67/88-C.E., dated 1-3-1988 and are not entitled to the concessional rate of duty.

Ratio Decidendi: A concessional exemption confined to specified goods cannot be extended to an unenumerated article merely because it may broadly answer the description of the general class of goods, and any doubt in an exemption entry must be resolved against the assessee.

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