Export customs duty depends on entry outwards date, so later exemption notification did not apply.

For exports, the relevant customs duty rate is the rate in force when entry outwards for the vessel is effected, not the date when loading commenced. A later change in duty does not alter the applicable rate once entry outwards has been granted. As entry outwards had been recorded before the exemption notification relied upon by the respondents, the exemption could not be extended to them. The respondents were therefore not entitled to exemption from customs duty.

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Issues: Whether the respondents were entitled to exemption from customs duty on exported goods with reference to the date on which loading commenced, or whether the decisive date was the date of entry outwards of the vessel.

Analysis: The governing principle applied was that, for exports, the relevant rate of customs duty is the rate prevailing when entry outwards for the vessel is effected, and any subsequent change in duty is irrelevant. As entry outwards in these matters had been granted before the notification relied upon by the respondents, the claimed exemption could not be extended to them.

Conclusion: The respondents were not entitled to the exemption from customs duty.

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