Supreme Court Clarifies Strict Interpretation of Customs Exemption Notifications; Burden on Assessee to Prove Applicability

The interpretation of exemption notifications in customs law has been clarified by the Supreme Court in the case of Commissioner of Customs (Import), Mumbai v. M/S Dilip Kumar and Company & Others. The court held that exemption notifications should be interpreted strictly, placing the burden on the assessee to prove applicability. If there is ambiguity, it should be resolved in favor of the revenue, not the assessee. This decision overruled previous judgments, including Sun Export Corporation v. Collector of Customs, Bombay. These principles were reaffirmed in the case of The State Of Maharashtra v. Shri Vile Parle Kelvani Mandal & Others.

---

---

---