Assembly Customs Act, 1962, Section 25(1) The material part of the notification reads as under: "In exercise of the powers conferred by sub-section (1) of Section 25 of the Customs Act, 1962 (52 of 1962), and in suppression of the notifications of the Government of India in the Ministry of Finance (Department of Revenue) Nos. 94/86-Customs and 95/86-Customs both dated 17-2-1986, the Central Government, being satisfied that it is necessary in the public interest so to do, hereby exempts parts required for the purpose of initial setting up, or for the assembly or manufacture of any article specified in column (2) of the Table hereto annexed, when imported into India and proved to the satisfaction of the Assistant Collector of Customs to be so required for such setting up, assembly or manufacture, from so much of that portion of the duty of customs leviable thereon which is specified in the corresponding entry in column (3) of the said Table...." The main ground on which the benefit of the aforesaid notification has been denied to the appellants is that serviceable parts out of the dismantled furnace were used besides some indigenous parts along with the imported parts and, therefore, a new furnace had not come into existence. The contention of learned counsel for the appellants is that the notification does not require that a new article must come into existence. We agree. The three expressions "initial setting up", "assembly" and manufacture" cannot be construed to mean the same thing. It is evident from the notification that the expression "assembly" has been separated from the expression "initial setting up". These expressions are intended to cover different situations. We are unable to accept the contention of learned Attorney General that the expression "assembly" is to take colour from the expression "initial setting up" and, therefore, without a new article coming into existence, the question of claiming benefit under the notification would not arise. The language of the notification is clear and plain. The notification is to be construed reasonably and rationally and not in a manner which deprives the benefit thereof. The expression "assembly" in the context and setting in which it has been used cannot be construed to mean bringing into (sic existence) of a new article. This expression cannot be equated with the expression "manufacture". If the construction as placed by the Tribunal is accepted, it would render the expression "assembly" in the notification redundant. The expression "assembly" has been used to opposed to dismantle. The notification does not contemplate denial of its benefit on the ground of reuse of certain parts and/or use of some indigenous parts with the imported parts. Thus, the appellants are clearly entitled to the benefit of the notification. [Shriram Vinyl & Chemical Industries v. Comr. of Customs, (2001) 4 SCC 186 (288)]