Ingot mould exemption under Notification 171/88 was read narrowly, defeating a refund claim for imported copper mould tubes.

Exemption under Notification No. 171/88 for ingot moulds was construed narrowly: the moulds had to be used in the factory of production for manufacture of steel ingots and melted during or after such production. The reference to the "factory of production" was read as the factory where the moulds were produced, not the factory where the ingots were made, and that reading defeated the claim for imported copper mould tubes. Even if the copper component could be treated as part of a mould, the notification's condition was not met on the facts, so the exemption was unavailable and the refund claim failed.

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Issues: Whether imported copper mould tubes were entitled to exemption under entry 1 of Notification No. 171/88 on the footing that they were ingot moulds used in the factory of production and melted during or after such production.

Analysis: The exemption covered ingot moulds subject to the condition that the moulds are used in the factory of production for manufacture of steel ingots and are melted during or after such production. On the facts, the imported goods were claimed to be copper mould tubes, and the Tribunal held that even if the copper portion could be treated as part of a mould, the notification's condition could not be satisfied in the case of imported goods. The reference to the factory of production was construed to mean the factory of production of the moulds, not the ingots, and the appellant's contrary interpretation was rejected on a plain reading of the notification.

Conclusion: The exemption was not available and the refund claim failed.

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