Exemption notification conditions cannot be expanded by circulars to require an end-use certificate when none is expressly prescribed.

An exemption under a notification cannot be denied on the basis of an end-use certificate unless that requirement is expressly stated in the notification itself. A circular cannot add a procedural condition not found in the exemption text, and the assessee's burden to establish eligibility does not justify importing extra requirements. In the absence of any explicit end-use stipulation, production of such a certificate cannot be treated as a precondition for exemption. The denial of exemption on that ground was therefore held unsustainable.

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Issues: Whether exemption under Notification No. 31/88 could be denied for want of an end-use certificate when the notification itself did not prescribe such a requirement.

Analysis: The exemption notification was examined and found to contain no condition requiring production of an end-use certificate. The burden on an assessee to establish entitlement to exemption did not justify adding a further procedural requirement not found in the notification. The Board's circular could not override the terms of the notification. In the absence of any express end-use stipulation, the exemption could not be made conditional upon production of such a certificate.

Conclusion: The denial of exemption on the ground of non-production of an end-use certificate was unsustainable and was set aside in favour of the assessee.

Ratio Decidendi: An exemption under a notification cannot be made subject to an end-use certificate unless that requirement is expressly provided in the notification itself.

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