Plain-meaning reading of exemption notification protects sandalwood oil made in a solvent extraction plant from denial of benefit.

An exemption notification covering goods manufactured in factories of specified industries must be applied according to its plain wording, and a process-based restriction not expressed in the text cannot be imported to narrow the benefit. Sandalwood oil produced by steam distillation at a solvent extraction plant was therefore treated as covered by Notification No. 115/75-C.E., because the appellant's factory fell within the specified industry and the product was manufactured there. The duty demand and connected penalties could not survive, and the assessee obtained consequential relief.

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Issues: Whether sandalwood oil manufactured by steam distillation at a solvent extraction plant was entitled to exemption under Notification No. 115/75-C.E. dated 30-4-75.

Analysis: The notification exempted goods falling under the tariff and manufactured in factories covered by the industries specified in the Schedule, subject to the specified exclusions. The restriction urged by the department, based on the manufacturing process, was not found in the notification. The appellant was admittedly a solvent extraction industry and the product was manufactured in that factory. The notification was construed on its plain terms, and the benefit could not be denied by reading into it a narrower process-based limitation. The earlier view that products of solvent extraction industries were independently exempt supported this construction.

Conclusion: Sandalwood oil manufactured by steam distillation at the appellant's solvent extraction plant was covered by the exemption.

Final Conclusion: The duty demand and connected penalties could not survive, and the appeal succeeded on merits with consequential relief.

Ratio Decidendi: An exemption notification granting benefit to goods manufactured in factories of a specified industry must be applied according to its plain words, and the benefit cannot be denied by importing a process-based restriction not expressed in the notification.

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