Strict construction of exemption notifications bars concessional duty for furniture parts not expressly covered.

An exemption notification granting concessional duty for non-wooden furniture was construed strictly according to its express terms. Because the notification exempted complete non-wooden furniture and did not specifically include parts, bus seats and back rests classifiable as furniture parts were held outside the concession. The text noted that where exemption for parts was intended, the notification said so expressly, as with steel furniture. On that reading, the concessional rate was unavailable for the disputed items, and the denial of exemption was upheld.

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Issues: Whether bus seats and back rests, being parts of furniture classifiable under CET sub-heading 9401.00, were eligible for the concessional rate of duty under Notification No. 80/90 dated 20-3-1990 as non-wooden furniture.

Analysis: The goods were not in dispute as to classification under the relevant tariff heading. The dispute turned on the scope of the exemption entry for non-wooden furniture. The notification exempted complete non-wooden furniture, while parts of such furniture were not specifically covered. The notification itself showed that where parts were intended to be exempted, they were expressly mentioned, as in the case of steel furniture. On that reading, parts of non-wooden furniture could not be brought within the exemption by implication.

Conclusion: The items in dispute, being parts and not complete furniture, were not entitled to the concessional rate of duty under Notification No. 80/90 dated 20-3-1990. The appeal failed.

Final Conclusion: The exemption was confined to complete non-wooden furniture and did not extend to parts such as bus seats and back rests, so the demand and denial of concessional duty were upheld.

Ratio Decidendi: An exemption notification granting concessional duty for furniture must be construed according to its express terms, and parts of furniture are not covered unless specifically included.

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