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The HC, in CUSAA 38/2023, interpreted the phrase "MIMO and LTE Products" in Serial No. 13(iv) of the amended Notification No. 24/2005 as applying solely to products combining MIMO technology and LTE standards. Consequently, the WAPs imported by the respondent, employing MIMO technology but not LTE standards, are entitled to the exemption from Basic Customs Duty. The court held that exemption notifications should be interpreted narrowly, and the conjunctive "and" in legal texts typically means a combination rather than alternatives.
The HC, in CUSAA 38/2023, interpreted the phrase "MIMO and LTE Products" in Serial No. 13(iv) of the amended Notification No. 24/2005 as applying solely to products combining MIMO technology and LTE standards. Consequently, the WAPs imported by the respondent, employing MIMO technology but not LTE standards, are entitled to the exemption from Basic Customs Duty. The court held that exemption notifications should be interpreted narrowly, and the conjunctive "and" in legal texts typically means a combination rather than alternatives.
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