JUDGMENT : The petitioner is stated to be a company engaged in foreign exchange and remittance business through several branches spread over metropolitan and major cities in the country, on the strength of an Authorised Dealers Category-II licence issued by the Reserve Bank of India under the provisions of the Foreign Exchange Management Act, 1999, (hereinafter referred to as ‘the FEMA’), and the Regulations issued thereunder. 2. The petitioner states that, in terms of the licence issued to it under the provisions of the FEMA, and the relevant regulations, the petitioner is permitted to import foreign currencies. It is stated that during the month of April 2024, the petitioner wanted to import certain foreign currencies consisting of Thai Baht, Malaysian Ringgit, Philippine Peso, Canadian Dollar, Japanese Yen, Chinese Yuan and Singapore Dollar through Yes Bank Ltd. It is stated that the bank had filed a Bill of Entry declaring the goods to be falling under Tariff Item No.49070020 of the First Schedule to the Customs Tariff Act, 1975, and sought to avail the benefit of the concessional rate of customs duty under Serial No. 304A of Notification No.50/2017-Customs dated 30-06-2017 as amended by Notification No.01/2020-Customs dated 02-02-2020 issued by the Department of Revenue, the Ministry of Finance, Government of India. It is stated that the 1st respondent, however, raised an objection that the benefit of the concessional rate of customs duty under Serial No. 304A of Notification No. 50/2017-Customs dated 30-06-2017 as amended by Notification No.01/2020-Customs dated 02-02-2020 was not available to the petitioner in respect of Canadian Dollars and Philippine Pesos, which were item numbers 3 and 4 in the Bill of Entry, on the premise that the exemption under the notification is available only for ‘paper money’ and not for ‘plastic/polymer notes’. Though the petitioner attempted to convince the 1st respondent that there is no difference between the paper money mentioned in the notifications referred to above and the currencies printed on plastic/polymer, the 1st respondent continued to take a stand that the benefit of the concessional rate of duty in terms of the notifications referred to above was not available to the petitioner. Since the petitioner was in dire need of the currency notes for the purposes of its business, the petitioner paid the duty demanded under protest. Reference is made in this regard to Ext.P6 communication. Since the petitioner was in dire need of the currency notes for the purposes of its business, the petitioner paid the duty demanded under protest. Reference is made in this regard to Ext.P6 communication. The Bill of Entry was processed by respondent No.1 disallowing the benefit of exemption in terms of the notifications referred to above and by holding that the benefit of such notifications was available only to currency notes made of paper and therefore did not extend to Canadian Dollars and Philippine Pesos, which were currencies printed on plastic/polymer. The order issued by the 1st respondent is on record as Ext.P7. The petitioner is thus before this Court challenging Ext.P7 communication alleging that the same is without jurisdiction and totally illegal. 3. A statement has been filed on behalf of respondent No.1. The learned Standing Counsel appearing for the 1st respondent refers to the said statement, where again the contention taken is that the benefit of the notifications referred to above is clearly applicable only to paper notes and not to plastic/polymer notes. It is contended that Ext.P7 order is an appealable order and it is for the petitioner to challenge Ext.P7 by filing an appeal before the Commissioner (Appeals) under Section 128 of the Customs Act, 1962. It is submitted that the notifications relied on by the petitioner for claiming the benefit of ‘NIL’ rate of duty are clearly not applicable in the facts and circumstances of the case, as it is admitted that the Canadian Dollars and Philippine Pesos, which were also subject matter of imports, are currencies printed on plastic/polymer and not on paper as contemplated by the exemption notifications. The learned Standing Counsel appearing for the 1st respondent would also submit that since the petitioner is claiming the benefit of an exemption notification, the same must be construed strictly and unless the imports of the petitioner were to clearly fall within the terms of the notification, the petitioner cannot be held entitled to the benefit of such notification. The learned Standing Counsel also referred to the judgment of the Supreme Court in Commissioner of Customs (Import), Mumbai v. Dilip Kumar and Co. The learned Standing Counsel also referred to the judgment of the Supreme Court in Commissioner of Customs (Import), Mumbai v. Dilip Kumar and Co. and others; (2018) 9 SCC 1 , to contend that exemption notifications must be construed strictly and unless the imports of the petitioner were to fall squarely within the terms of the notification, it is not entitled to the benefit of the notification. 4. The learned counsel appearing for the petitioner would rely on the judgment of the Supreme Court in Orient Traders v. Commercial Tax Officer, Tirupati; (2008) 12 SCC 440 , and in particular to paragraph No.16 thereof, where the Supreme Court referred to the judgment of that Court in Deputy Commissioner of Sales Tax (Law), Board of Revenue (Taxes), Ernakulam vs. G.S. Pai and Co.; (1980) 1 SCC 142 , which holds that it is a cardinal rule of interpretation that while interpreting entries in tax legislation, the words used in the entries must be construed not in any technical sense nor from the scientific point of view but as understood in common parlance. 5. Having heard the learned counsel appearing for the petitioner and the learned Standing Counsel appearing for the 1st respondent, I am of the view that the petitioner is entitled to succeed. Ext.P2 is a copy of the Notification bearing No.50/2017-Customs dated 30-06-2017 issued by the Department of Revenue, Ministry of Finance, Government of India. Ext.P2 notification has been amended by Notification No.01/2020-Customs dated 02-02-2020 (Ext.P3) by the Department of Revenue, Ministry of Finance, Government of India, where Serial No. 304A has been incorporated as under: Sl.No Chapter Heading or sub-heading or tariff item Description of Goods Standard Rate Integrated Goods and Services Tax Condition No. (1) (2) (3) (4) (5) (6) 304A 4907 00 20 Paper Money Nil Nil - It is true that Ext.P3 notification uses the words ‘Paper Money’. There seems to be no qualitative or other difference in the currency notes printed on paper and currency notes printed on plastic/polymer. In order to ensure the durability of the currency notes, some countries in the world have shifted the printing of the currency notes to plastic/polymer medium, which cannot be easily spoiled or mutilated. Such notes are also reported to have higher security features for preventing counterfeit currencies from being printed. Currencies printed on plastic/polymer medium, apart from being waterproof, dirt-proof and durable, are also recyclable. Such notes are also reported to have higher security features for preventing counterfeit currencies from being printed. Currencies printed on plastic/polymer medium, apart from being waterproof, dirt-proof and durable, are also recyclable. The fact that certain countries have shifted printing of currencies to plastic/polymer medium cannot take away the fact that they continue to be currencies, as distinct from coins. The only reasonable interpretation that can be given to entry 304A of Ext.P3 notification is that paper currencies are to be distinguished from coins and the word ‘Paper Money’ will also include currencies printed on plastic/polymer medium. Though the learned Standing Counsel is right in contending on the strength of the judgment of the Supreme Court in Dilip Kumar (Supra) that exemption notifications are to be strictly construed, I am of the view that even if strict construction is placed on Ext.P2 notification (as amended by Ext.P3 notification), the meaning to be ascribed to 'Paper Money' will include currencies printed on plastic/polymer medium and the only effect of using the words ‘Paper Money’ in Ext.P3 notification is that no person will be able to import currencies in coin form. In Orient Traders (Supra) the Supreme Court extracted the judgment of the Court in G.S. Pai (Supra) where it was held: "We will first consider the question whether the ornaments and other articles of gold purchased by the assessee fall within the description of "Bullion and specie" given in Entry 56. There are two expressions in this Entry which require consideration; one is "bullion" and the other is "specie". Now there is one cardinal rule of interpretation which has always to be borne in mind while interpreting entries in sales tax legislation and it is that the words used in the entries must be construed not in any technical sense nor from the scientific point of view but as understood in common parlance. We must give the words used by the Legislature their popular sense meaning "that sense which people conversant with the subject-matter with which the statute is dealing would attribute to it". The word "bullion" must, therefore, be interpreted according to ordinary parlance and must be given a meaning which people conversant with this commodity would ascribe to it. Now it is obvious that "bullion" in its popular sense cannot include ornaments or other articles of gold. The word "bullion" must, therefore, be interpreted according to ordinary parlance and must be given a meaning which people conversant with this commodity would ascribe to it. Now it is obvious that "bullion" in its popular sense cannot include ornaments or other articles of gold. "Bullion" according to its plain ordinary meaning means gold or silver in the mass. It connotes gold or silver regarded as raw material and it may be either in the form of raw gold or silver or ingots or bars of gold or silver. The Shorter Oxford Dictionary gives the meaning of "bullion" as "gold or silver in the lump; also applied to coined or manufactured gold or silver considered as raw material. "So also in Jowitt's Dictionary of English Law and Wharton's Law Lexicon we find that the following meaning is given for the word "bullion": "uncoined gold and silver in the mass. These metals are called so, either when melted from the native ore and not perfectly refined, or where they are perfectly refined, but melted down into bars or ingots, or into any unwrought body, of any degree of fineness". It would, therefore, be seen that ornaments and other articles of gold cannot be regarded as "bullion" because, even if old and antiquated, they are not raw or unwrought gold or gold in the mass, but they represent manufactured or finished products of gold. Nor do they come within the meaning of the expression "specie". The word "specie" has a recognized meaning and according to Webster's New World Dictionary, it means "coin, as distinguished from paper money". The Law Dictionaries also give the same meaning. Wharton's Law Lexicon and Jowitt's Dictionary of English Law state the meaning of "specie" as "metallic money" and in Black's Law Dictionary, it is described as "coin of the precious metals, of a certain weight and fineness, and bearing the stamp of the Government, denoting its value as currency" while "Words and Phrases Permanent Edition-Vol. 39A" also gives the same meaning. 39A" also gives the same meaning. Therefore, according to common parlance, the word "specie" means any metallic coin which is used as currency and if that be the true meaning, it is obvious that ornaments and other articles of gold cannot be described as "specie"…" Therefore, I believe that the word ‘Paper Money’ in Ext.P3 notification will also extend to currencies printed on plastic/polymer medium, and the exemption will not be available only if a person decides to import currencies in the form of coins as distinct from currency in the form of notes. In light of the above, the writ petition is allowed. Ext.P7 is quashed. The first respondent is directed to pass fresh orders taking note of the findings in this judgment within one month from the date of receipt of a certified copy of this judgment.