Captive-use exemption for printing cylinders upheld where tariff classification matched the notification and departmental clarification supported coverage.

Nickel rotary printing cylinders classified under sub-heading 8442.00 were treated as eligible for exemption under Notification No. 201/87 when used captively. The notification covered printing frames in the same tariff classification, and the departmental clarification stated that designed screens and cylinder screens were also exempt in captive use. As the classification was undisputed and no contrary material was produced, the exemption was upheld on the basis of the notification text and the clarification, and the Revenue's challenge failed.

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Issues: Whether nickel rotary printing cylinders were entitled to the benefit of Notification No. 201/87 when used captively.

Analysis: The notification granted exemption to printing frames classifiable under sub-heading 8442.00. The cylinders in question were also classifiable under the same sub-heading, and their classification was not disputed. The relevant departmental clarification stated that designed screens and cylinder screens were eligible for exemption when used captively, and no contrary material was produced.

Conclusion: The benefit of the notification was available to the goods in question and the appeal failed.

Final Conclusion: The exemption was upheld on the basis of the notification language and the departmental clarification, resulting in dismissal of the Revenue's challenge.

Ratio Decidendi: Where the goods fall within the notified tariff classification and the departmental clarification supports captive-use exemption, the exemption cannot be denied in the absence of contrary evidence.

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