Exemption notification eligibility depends on its conditions, not tariff classification alone, for blended lubricating oils.

Exemption under Notification No. 120/84-C.E. was available to lubricating oils manufactured by straight blending of duty-paid mineral oils, because the notification turned on satisfaction of its own conditions and not on placement under a particular tariff heading. The goods were shown to be blended from duty-paid base mineral oils, and no non-compliance with the notification was established. Classification under a residuary sub-heading did not defeat relief where the exemption covered the described class of goods without linking it to any specific tariff entry. The operative principle is that eligibility for such an exemption depends on the notification's conditions, not tariff classification alone.

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Issues: Whether the impugned lubricating oils, manufactured by straight blending of duty-paid mineral oils and classified under the residuary tariff sub-heading, were entitled to exemption under Notification No. 120/84-C.E.

Analysis: The notification exempts blended or compounded lubricating oils obtained by straight blending of mineral oils or by blending or compounding mineral oils with other ingredients, provided the mineral oils used are duty paid. The relevant inquiry is whether the goods satisfy the notification's own conditions; tariff classification by itself is not ative where the notification does not confine the exemption to any particular heading or sub-heading. The record showed that the products were manufactured by blending duty-paid base mineral oils, and the Revenue did not dispute that process or establish non-compliance with the notification's conditions. The fact that the goods were placed under the residuary sub-heading did not defeat the exemption, since the notification applied to lubricating oils meeting its terms without reference to tariff heading.

Conclusion: The benefit of Notification No. 120/84-C.E. was available to the impugned products, and the appeal succeeded.

Final Conclusion: Exemption was held admissible on satisfaction of the notification's conditions, irrespective of the goods' placement under the residuary tariff entry.

Ratio Decidendi: Where an exemption notification grants relief to a described class of goods without linking it to a specific tariff heading, eligibility depends on fulfillment of the notification's conditions and not on the tariff classification alone.

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