Exemption notification interpreted strictly for newsprint supplied to a registered newspaper; duty demand and penalty could not stand.

Newsprint supplied against a purchase order placed by a newspaper registered with the Registrar of Newspapers for India satisfied Sl. No. 69 of Notification No. 5/97-C.E.; the exemption condition was therefore met. In interpreting an exemption notification, its scope cannot be enlarged by reading in requirements not expressed in the text, so the authority could not go beyond the notification to test whether GETIT Yellow Pages was a newspaper in a broader sense. The assessee was entitled to exemption, and the duty demand and penalty could not be sustained.

---

---

Issues: Whether the newsprint supplied for publishing GETIT Yellow Pages satisfied the condition of Sl. No. 69 of Notification No. 5/97-C.E. dated 5-1-97, and whether duty and penalty could therefore be sustained.

Analysis: The exemption notification required only that the newsprint be supplied against a purchase order placed by a newspaper registered with the Registrar of Newspapers for India. That condition was admitted to be fulfilled. In interpreting an exemption notification, the scope cannot be enlarged by importing considerations not found in the notification itself. The authority below, therefore, was not justified in going beyond the express language of the notification and examining whether GETIT Yellow Pages was a newspaper in a broader sense.

Conclusion: The assessee satisfied the notification condition and was entitled to exemption. The duty demand and penalty could not be sustained.

---