S.B. SINHA, J.

Leave granted.

2. Interpretation of the expression "substitute" falls for determination in this appeal which arises out of a judgment and order dated 30.01.2004 passed by a Division Bench of the Andhra Pradesh High Court in Writ Petition No.21674 of 2002.

3. Shorn of all unnecessary details, the fact of the matter is as under:

The Respondent herein is an Association of the cultivators of tobacco. An incentive scheme was introduced by the Government of India in the year 1997 as regard export and import in terms of the Duty Entitlement Pass Book Scheme, whereby and whereunder 2% incentive was provided out of the export carried from the notified container depots. Guntur was not mentioned in the notification dated 7.4.1997 issued pursuant to or in furtherance of the said policy decision which came into force with effect from 1.4.1997. In terms of the said notification exemption was granted from payment of additional duty leviable under Section 3 of the Customs Tariff Act to those who had been issued a Duty Entitlement Pass Book by the Licensing Authority. Sub-clause (iv) of Clause (2) of the said notification states :

"(iv) The said Duty Entitlement Pass Book shall be valid