Exemption for lubricating oils depends on notification conditions, not tariff heading restrictions, where blending criteria are satisfied.

Notification No. 120/84-C.E. granted exemption to lubricating oils generally, and eligibility turned on whether the product satisfied the notification's own conditions. Spindle Oil-22 was found to be a blended or compounded lubricating oil made from duty-paid base mineral oils, and the Revenue did not dispute that blending process. The tariff classification exclusion did not defeat the exemption because the notification did not tie relief to any particular heading. An earlier decision in the assessee's own matter had reached the same result on the same principle.

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Issues: Whether the benefit of Notification No. 120/84-C.E. dated 11-5-84 was available to the product Spindle Oil-22.

Analysis: The product was found to be a blended or compounded lubricating oil obtained from duty-paid base mineral oils, and the Revenue did not rebut the blending process. The notification exempted lubricating oils without linking the benefit to any particular tariff heading, so all lubricating oils satisfying the notification conditions were eligible. The earlier decision in the appellants' own case had already held that the exclusionary wording in the tariff classification did not defeat exemption under the notification where the notification itself did not impose such a limitation.

Conclusion: The benefit of Notification No. 120/84-C.E. was available to the product, and the appeal succeeded in favour of the assessee.

Ratio Decidendi: Where an exemption notification covers lubricating oils in general and its conditions are satisfied, tariff classification restrictions not found in the notification itself cannot be used to deny the exemption.

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