Exemption notifications must be read as written; unqualified tariff entries cannot be narrowed by implication.

Pre-painted aluminium zinc alloy coated sheets in coil were treated as falling within Notification No. 11/97-Cus. because the relevant entry covered cold rolled coils simpliciter, without qualifying words limiting the exemption. The commentary applies the principle that exemption notifications must be construed on their own terms, and that no additional restriction can be implied where the legislature has not used limiting language. By comparing the broad wording of the relevant entry with other entries in the same table that expressly imposed conditions, it concludes that the benefit could not be narrowed by intendment and the denial of exemption was unsustainable.

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Issues: Whether pre-painted aluminium zinc alloy coated sheets in coil, described as further worked cold rolled coils, were eligible for the benefit of Notification No. 11/97-Cus. dated 01.03.1997.

Analysis: The entry at S. No. 105 of the notification covered cold rolled coils simpliciter, while other entries in the same table, such as S. No. 114, expressly used qualifying words to limit the scope of exemption where the legislature intended to do so. The absence of similar restricting language against S. No. 105 indicated that no further condition could be read into the exemption. The legal principle applied was that exemption notifications must be construed on their own terms and nothing can be supplied by intendment.

Conclusion: The goods were held to fall within the notification and the denial of exemption was unsustainable, in favour of the assessee.

Ratio Decidendi: Where an exemption notification grants benefit to a class of goods without qualifying words, the scope of the entry cannot be restricted by implication or intendment.

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