Exemption notification for specified goods cannot cover imports with added components that alter their character

An exemption notification confined concessional duty to Winchester Disk Drives alone, and the imported goods were held outside that entry because they were Winchester Disk Drives with Controller. The added controller was treated as an additional component that altered the character of the goods, so the concession could not be extended merely because the equipment performed related functions. The earlier authority relied on by the assessee was distinguished on facts, and the exemption claim failed; the order granting exemption was set aside and the Revenue succeeded.

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Issues: Whether Winchester Disk Drive with Controller imported by the assessee was entitled to the benefit of Notification No. 281/84-Cus. dated 19-11-1984.

Analysis: The notification granted concessional duty only to Winchester Disk Drives. The imported goods were Winchester Disk Drive with Controller, and the controller was treated as an additional component that altered the nature of the goods and took them outside the notification entry. The earlier decision relied upon by the assessee was distinguished on facts, and the concession could not be extended merely because the equipment could perform related functions.

Conclusion: The goods were not covered by the exemption notification, and the claim to concessional duty failed.

Final Conclusion: The impugned order granting exemption was set aside and the Revenue succeeded in the appeal.

Ratio Decidendi: An exemption notification confined to specified goods cannot be extended to imported goods that include an additional component which changes their character and places them outside the stated entry.

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