Tariff-based exemption construed to include stainless steel tubes and pipes absent express exclusion.

An exemption notification using tariff language must be construed consistently with the tariff meaning unless the goods are expressly excluded. Because the tariff treated steel as including stainless steel, and the notification did not expressly exclude stainless steel tubes and pipes, the exemption was available to those goods. The omission to name stainless steel separately in the relevant entry did not justify denial of relief. The Revenue's challenge accordingly failed.

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Issues: Whether the benefit of Notification No. 202/88 dated 20-5-1988 was available to stainless steel tubes and pipes.

Analysis: The notification granted exemption to tubes and pipes blanks, and the word used in the exemption had to be read in the sense in which it was understood in the tariff. The relevant tariff note treated steel as including stainless steel, and the notification itself referred to stainless steel and other alloy steel in one of its entries. In the absence of any express exclusion of stainless steel tubes and pipes, the exemption could not be denied merely because the notification did not separately name stainless steel in the relevant entry.

Conclusion: The benefit of the notification was available to stainless steel tubes and pipes, and the Revenue's challenge failed.

Ratio Decidendi: Where an exemption notification uses a tariff expression, that expression is construed consistently with the tariff unless the notification expressly excludes the goods.

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