Strict construction of customs exemptions denied concession for brake components, while limitation restricted differential duty to timely Bills of Entry.

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....Strict interpretation of the customs exemption required Disc Brake Units and Pole Wheels to fall clearly within the recognised railway-engineering meaning of a Train Protection and Warning System (TPWS). As components of a mechanical or pneumatic axle-mounted braking system, rather than signal-based TPWS equipment, they did not qualify for concessional duty. Official railway specifications prevailed over contrary technical opinions. Differential customs duty could be demanded only for Bills of Entry within the normal limitation period invoked under section 28(1); extending the demand beyond that period under section 28(4) exceeded the show cause notice. The exemption claim failed, while the demand was restricted accordingly.....