Judgment

RANGANATHAN, J.:- These are appeals under Section 130E(b) of the Customs Act from an order passed by the Customs, Excise and gold Appellate Tribunal dismissing the appeals preferred by the Collector of Customs in the cases of M/s. Hunsur Plywood Pvt. Ltd. and M/s. Veneer Mills. The question raised involves the interpretation of Notifications Nos. 59/83 and 126/84. These notifications are identically worded in all material respects with Notification No, 265/Cus. dated 8-12-1982 and the question before us is directly governed by our judgment of even date in Civil Appeals Nos. 2644/48 of 1987 (Collector of Customs v. Western India Plywood Manufacturing Co. Ltd.) (reported in AIR 1990 SC 755). For the reasons set out in detail in the said judgment these appeals have to be allowed and the orders of the Assistant Collector rejecting the claims filed by the respondents have to be upheld.

2. When these matters were taken up, Shri V. Sridharan, appearing on behalf of the assessee-respondents, drew our attention to Section 5 of the Customs Tariff Act. He contended that exemptions or concessions in respect of goods imported from certain countries are generally granted in pursuance of a