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Issues: Whether the imported signal generator was entitled to concessional duty under Notification No. 118/80-Cus. on the ground that its frequency range included operation above 1000 MHz.
Analysis: The notification granted concessional duty to signal generators of frequency above 1000 MHz. The imported equipment had an upper frequency limit of 1750 MHz and therefore fell within the notified description. The fact that a signal generator may also cover lower frequency ranges did not exclude it from the benefit of the notification, especially where the technical nature of such equipment made operation above 1000 MHz dependent upon a range that may include lower frequencies. The notification was construed according to its evident object of extending the concession to generators capable of operating above 1000 MHz.
Conclusion: The imported signal generator qualified for the concessional benefit, and the Revenue's challenge failed.