Exemption notification must be applied as written; no extra condition can be added to deny precious metals concession.

An exemption notification for articles of precious metals covered articles re-made from old and used articles, or re-conditioned, re-fabricated, or similarly processed articles. The text emphasises that the notification did not impose any further condition requiring customers to supply the old and used platinum articles. Once re-conditioning or re-making was established, the department could not deny the concession by adding a condition not found in the notification. The stated principle is that an exemption notification must be applied strictly according to its terms, and no extra condition may be read into it to refuse the exemption.

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Issues: Whether the respondents were entitled to the concession under Notification No. 131/81 dated 22-6-81, as amended, for articles of platinum that were re-made or re-conditioned without a separate condition that old and used articles must have been supplied by customers.

Analysis: The relevant notification required that articles of precious metals be re-made from old and used articles, or be re-conditioned, re-fabricated, or subjected to a similar process. The absence of any additional condition in the notification that customers must supply old and used platinum articles was material. Once it was accepted that the articles had been re-conditioned or re-made, the denial of the concession on the added condition imposed by the department was not sustainable.

Conclusion: The respondents were entitled to the benefit of the notification, and the departmental appeal failed.

Ratio Decidendi: An exemption notification must be applied according to its terms, and a condition not found in the notification cannot be read into it to deny the exemption.

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