Bonded warehouse exemption must be read strictly; later enlarging notification cannot rewrite earlier customs relief.

An exemption notification covering goods manufactured in a bonded warehouse must be read strictly on its own terms: the goods had to fall within the specified tariff sub-headings and be manufactured in bond under Section 65 of the Customs Act, with duty becoming chargeable on removal for home consumption under Section 15(2). On that construction, the earlier notification was workable and did not require supplementation. A later notification enlarging the exemption to raw materials, components and parts used in manufacture in bond could not be used to explain or rewrite the earlier notification, especially because it was not in force when the imports were made. The claimed exemption was therefore unavailable.

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Issues: Whether hot rolled steel plates imported in 1989 were entitled to exemption under Notification No. 237/87 on the basis that the notification covered goods manufactured in a bonded warehouse, and whether Notification No. 33/91 could be relied upon to construe the earlier notification.

Analysis: The exemption was confined to goods falling under the specified tariff sub-headings and manufactured in a warehouse in accordance with Section 65 of the Customs Act, 1962. Goods may be imported, kept in a bonded warehouse without payment of duty, and subjected to manufacturing operations there; upon removal for home consumption, duty is attracted at the rate in force under Section 15(2) of the Customs Act, 1962. On that construction, the earlier notification was capable of operation and was not or unworkable. The later Notification No. 33/91 merely extended the exemption to raw materials, components and parts used in manufacture in bond and did not show that it was intended to explain or correct the earlier notification, especially as it was not in force when the imports were made.

Conclusion: The imported plates were not shown to fall within the exemption, and the later notification did not aid the appellant. The appeal failed.

Final Conclusion: The exemption under the earlier notification was not available on the facts, and the duty demand was sustained.

Ratio Decidendi: An exemption notification covering goods manufactured in a bonded warehouse must be construed on its own terms, and a later, enlarging notification cannot be used to rewrite or explain an earlier notification when it was not operative at the relevant time.

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