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    <title>2017 (9) TMI 335 - CESTAT NEW DELHI</title>
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    <description>Exemption notifications must be construed strictly according to their express wording, and the scope of Heading 90.21 cannot be extended to cover surgical implants as &quot;artificial limbs and rehabilitation aids for the handicapped&quot; where that phrase is used more narrowly in the notification. On that basis, the goods were held outside Notification No. 71/86-C.E., and the duty demand for the relevant period, with penal consequences, was sustained. Small scale industry exemption was also unavailable because the goods were cleared under the brand names of the foreign collaborator, which attracted the brand-name restriction under the SSI notifications. The exemption claims therefore failed on both grounds and the remaining duty demands were upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=347578</link>
      <description>Exemption notifications must be construed strictly according to their express wording, and the scope of Heading 90.21 cannot be extended to cover surgical implants as &quot;artificial limbs and rehabilitation aids for the handicapped&quot; where that phrase is used more narrowly in the notification. On that basis, the goods were held outside Notification No. 71/86-C.E., and the duty demand for the relevant period, with penal consequences, was sustained. Small scale industry exemption was also unavailable because the goods were cleared under the brand names of the foreign collaborator, which attracted the brand-name restriction under the SSI notifications. The exemption claims therefore failed on both grounds and the remaining duty demands were upheld.</description>
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