In Brief
The Supreme Court upheld customs authorities' denial of exemption from import duty to Gujarat Ambuja Exports Limited for crude palm oil. The company imported crude palm oil under a notification allowing concessional duty when goods are used to manufacture non-edible products like industrial fatty acids. However, the company processed the oil to produce 75% refined edible oil and 25% Palm Fatty Acid Distillate as a by-product. The Court held that exemption notifications must be strictly construed; since the primary product was edible oil, the exemption conditions were not satisfied. The Court overturned the tribunal's reliance on tariff classification guides, confirming that exemption entitlements depend strictly on fulfilling all specified notification conditions."
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