Strict construction of exemption notifications denies relief for parts of jigs and fixtures not expressly covered.

Exemption notifications must be strictly construed according to their express terms, and benefit cannot be extended by implication to goods not specifically covered. Notification No. 220/86-C.E. granted exemption to jigs and fixtures, but it did not expressly extend that relief to parts of jigs and fixtures. On that basis, the parts were held ineligible for exemption and duty relief was rejected.

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Issues: Whether parts of jigs and fixtures were entitled to the benefit of Notification No. 220/86-C.E. dated 02.04.1986.

Analysis: The notification granted exemption only to jigs and fixtures. It did not contain any express exemption for parts of jigs and fixtures. Exemption notifications are to be construed strictly and read as they stand, without adding words or extending the benefit by implication.

Conclusion: The parts of jigs and fixtures were not eligible for exemption under Notification No. 220/86-C.E. dated 02.04.1986, and the appeal failed.

Final Conclusion: The denial of exemption was upheld and the claim for duty relief on parts of jigs and fixtures was rejected.

Ratio Decidendi: An exemption notification must be strictly construed and cannot be extended to goods not expressly covered by its terms.

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