Exemption for imported greasy wool applied under tariff wool classification; pollution concerns could not justify differential duty.

Imported raw greasy wool was treated as the first stage of scoured wool and as falling within the tariff description of wool under sub-heading 51.01 and Notification No. 50/87-C.E., so the exemption from countervailing duty applied. The Tribunal reasoned that denying exemption to raw or greasy wool while extending it to processed wool would produce an anomalous result. Concerns about pollution were not treated as a basis for differential duty, because such issues could be addressed by fumigation measures. The Revenue's challenge was rejected and the exemption benefit was allowed for the imported greasy wool.

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Issues: Whether raw greasy wool imported by the assessee was covered by Notification No. 50/87-C.E. and sub-heading 51.01 so as to qualify for exemption from countervailing duty.

Analysis: The Tribunal accepted the lower appellate authority's view that greasy raw wool was at the first stage of scoured wool and fell within the description of wool contemplated by the tariff entry and the exemption notification. It also held that denying exemption to raw or greasy wool while granting it to processed wool would create an anomalous result. The concern of pollution was held to be a matter capable of being addressed by fumigation and not by imposing a differential rate of duty.

Conclusion: The benefit of the exemption notification was held to be available to the imported greasy wool, and the Revenue's challenge was rejected.

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