Strict construction of exemption notifications excludes composite radio cassette goods from a specific radio set exemption.

An exemption notification must be construed strictly, so benefit cannot be extended to composite goods merely because they fall within a broad tariff heading. Radio sets with in-built sound recording and reproducing facilities were held not to answer the description "radio sets including transistor sets" under Notification No. 57/93-CE. Because the notification specifically limited the exemption to that description, the composite radio cassette type goods were treated as falling under the residual entry for "all other goods" under the same sub-heading. The result was that the exemption claim under Sl. No. 10(a) failed and the goods were correctly classified under Sl. No. 10(b).

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Issues: Whether radio sets with in-built sound recording and sound reproducing facility were entitled to exemption under Notification No. 57/93-CE as "radio sets including transistor sets" under Sl. No. 10(a), or whether they fell under the residual entry for "all other goods" under Sl. No. 10(b).

Analysis: Heading No. 85.27 was broadly worded to cover reception apparatus for radio broadcasting, even when combined in the same housing with sound recording or reproducing apparatus. However, the exemption notification used a narrower description and granted the benefit under Sl. No. 10(a) only to radio sets including transistor sets, while Sl. No. 10(b) covered all other goods classifiable under sub-heading 8527.00. A combination product with in-built recording and reproducing facility was not treated in trade or common parlance as a mere radio set. Where the notification specifically described the exempted goods, the exemption could not be extended by interpretation to composite products not squarely covered by that description.

Conclusion: The composite radio cassette type goods were not covered by Sl. No. 10(a) of Notification No. 57/93-CE and were correctly treated as falling under Sl. No. 10(b). The appeal failed.

Ratio Decidendi: An exemption notification must be construed strictly, and where the notification grants benefit only to goods specifically described, composite products not answering that description cannot claim the exemption on a broad tariff classification alone.

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