Computer exemption confined to complete systems; parts and peripherals were held outside Notification No. 282/84.

An exemption notification for computers was construed strictly on eligibility, and the imported memory modules, peripherals and spares were held not to be complete computers. Because the goods were only parts and accessories, they did not fall within the notification's expression "computers", and the concessional exemption under Notification No. 282/84 was denied. The requirement of certification from the Department of Electronics did not enlarge the basic scope of the exemption. The appeals therefore failed, and the denial of concessional duty was upheld.

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Issues: Whether memory modules, computer peripherals and spares imported by the appellants could be treated as "computers" so as to qualify for concessional exemption under Notification No. 282/84.

Analysis: The notification granted exemption to computers of the specified tariff headings and required certification from the Department of Electronics regarding the non-availability of such computers in India. The imported goods were admittedly not complete computers. Exemption notifications must be construed strictly on the question of eligibility, though procedural requirements may be viewed liberally after the basic entitlement is established. Since the goods imported were only parts and peripherals, they did not fall within the expression "computers" in the notification.

Conclusion: The imported goods were not eligible for exemption under Notification No. 282/84 and the denial of concessional duty was correct.

Final Conclusion: The appeals failed because the exemption was confined to complete computers and could not be extended to computer parts and peripherals.

Ratio Decidendi: An exemption notification granting relief to computers cannot be extended to imported parts or peripherals which are not themselves complete computers, and eligibility must be strictly established.

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