Exemption for incomplete pumps upheld where tariff and notification used the same wording and plain meaning controlled.

Incomplete pumps were considered for exemption under Notification No. 155/86 where the tariff entry and the notification used similar language. The same meaning was applied to the expression in both provisions, following the earlier decision relied on, and interpretative rules were not used to enlarge the exemption beyond its plain scope. On that basis, the item was treated consistently with the tariff classification and the notification, and the exemption claim was accepted.

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Issues: Whether the appellant was entitled to exemption under Notification No. 155/86 in respect of incomplete pumps, when the tariff entry and the notification entry both used similar words for pumps.

Analysis: The tariff entry and the notification both related to pumps and the wording used in each was alike. In such a situation, the same understanding of the expression was applied as in the earlier decision relied upon, and the interpretative rules were not used to enlarge the scope of the exemption notification. The item was therefore treated consistently with the tariff entry and the notification.

Conclusion: The exemption claim was accepted and the appeal succeeded.

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