Customs exemption for ocean-going vessels does not cover imported spares where the notification is clear and limited.

An exemption notification that covered only ocean-going vessels, excluding vessels imported for breaking up, did not extend to separately imported spares because the text made no reference to spares. Arguments based on the meaning of spares, Section 87 of the Customs Act, 1962, and later exemption notifications were rejected as irrelevant where the governing notification was clear and unambiguous. The imported spares were therefore outside the exemption and duty relief was denied.

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Issues: Whether the exemption under Notification No. 262/58-Cus. dated 11-10-1958 extended to spares imported along with an ocean-going vessel.

Analysis: The notification exempted only ocean-going vessels, other than vessels imported to be broken up, from customs duty. It contained no reference to spares. The contention based on the definition of spares and on Section 87 of the Customs Act, 1962, as well as reliance on later exemption notifications, was held to be irrelevant where the notification in force during the relevant period was clear and unambiguous.

Conclusion: The spares imported by the appellant were not covered by the exemption notification, and the denial of exemption was upheld.

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