Exemption for superfinishing machines turns on capability to achieve the notified surface finish, not exclusive limitation to it.

An exemption entry referring to a superfinishing machine "capable of achieving" a specified roughness average range is satisfied where the imported machine can attain that notified finish, even if it is also capable of producing a better surface finish. The operative test is capability to achieve the prescribed range, not confinement exclusively to that range. On the facts, the machine's ability to achieve 0.03 Ra necessarily meant it could achieve the lesser finish within the notified 0.05 Ra to 0.1 Ra range, so it fell within Notification No. 154/86-Cus. and qualified for exemption.

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Issues: Whether a superfinishing machine capable of achieving a better surface finish than the range specified in Notification No. 154/86-Cus. could still qualify for the exemption.

Analysis: The notification used the expression "capable of achieving" a specified roughness average range. The machine imported was found capable of achieving 0.03 Ra, which necessarily meant that it could also achieve the lesser finish within the notified range of 0.05 Ra to 0.1 Ra. The wording of the exemption did not require the machine to be confined only to that range; the relevant test was whether it was capable of achieving the notified finish.

Conclusion: The machine satisfied the notification entry and was entitled to the exemption. The Revenue's appeal was without merit.

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