Exemption notification must be read as written: parts for briquetting presses qualified despite general-use capability.

Imported taper roller bearings claimed as parts of power-operated coal briquetting presses were held to fall within Notification No. 113/81-Cus. because the notification required only that the parts be meant for use in briquetting presses for compacting cellulosic waste material. Their capability of general use did not defeat exemption where no further end-use restriction appeared in the notification, and the machine itself was not required to be imported. The document states that a condition not expressed in the exemption cannot be added by implication, so the goods satisfied the notification and the Revenue's challenge failed.

---

---

Issues: Whether imported taper roller bearings, claimed as parts of power-operated coal briquetting presses, were entitled to exemption under Notification No. 113/81-Cus. even though they were capable of general use and the machine itself was not imported.

Analysis: The notification required only that the parts be meant for use in briquetting presses for compacting cellulosic waste material. The imported bearings were supported by the catalogue as components of such presses. A use for other machines or general applications did not, by itself, defeat the exemption because no additional end-use restriction was expressed in the notification. A condition not found in the notification cannot be imported by implication.

Conclusion: The goods satisfied the terms of the exemption notification and were eligible for the benefit. The Revenue's challenge failed.

Ratio Decidendi: An exemption notification must be construed according to its express language, and a further end-use restriction cannot be read into it unless the notification itself so provides.

---