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    <title>2022 (5) TMI 745 - CESTAT MUMBAI</title>
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    <description>Exemption notifications in fiscal law must be construed strictly according to their plain wording, and courts cannot supply omissions or adopt a broader purposive reading. On that approach, imported goods described as &quot;Skin Barriers Micropore Surgical Tapes&quot; were held not to match the notification description, so exemption was denied. The extended period of limitation could not be invoked because the imports had been regularly assessed on the same description and suppression or misrepresentation was not established. Penalties were therefore not sustainable, while the duty demand survived for the normal period.</description>
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      <description>Exemption notifications in fiscal law must be construed strictly according to their plain wording, and courts cannot supply omissions or adopt a broader purposive reading. On that approach, imported goods described as &quot;Skin Barriers Micropore Surgical Tapes&quot; were held not to match the notification description, so exemption was denied. The extended period of limitation could not be invoked because the imports had been regularly assessed on the same description and suppression or misrepresentation was not established. Penalties were therefore not sustainable, while the duty demand survived for the normal period.</description>
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