Exemption Denial

In a decisive ruling, CESTAT Ahmedabad has drawn a sharp line between “Calcium Nitrate” and “Boronated Calcium Nitrate,” denying concessional customs duty to the latter despite compositional overlap. 

The Tribunal reinforces two core principles: exemption notifications must be construed strictly, and Section 28 remains a valid statutory route to reopen assessments without prior appeal against Bills of Entry. 

The decision signals a continued judicial preference for textual precision over commercial equivalence in exemption matters.