Clarificatory amendment to exemption notification treated as retrospective where no new substantive condition was introduced.

An amendment substituting references to an earlier exemption notification with a later one was treated as clarificatory because it did not introduce any new substantive condition. On that basis, Notification No. 18/97 dated 10.04.1997 was regarded as operating retrospectively, reflecting a continuation of the existing exemption framework rather than a prospective change in law. The Tribunal relied on cited precedents to support the view that such substitution indicates clarification of the intended position. The Revenue's appeal therefore failed.

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Issues: Whether Notification No. 18/97 dated 10.04.1997 was clarificatory in nature and therefore retrospective in operation.

Analysis: The Tribunal noted the amendment made to the earlier notification by substituting the words and figures referring to the prior exemption notification with the later notification. Relying on the cited judicial precedents, it treated such substitution as indicative of a clarificatory amendment rather than a prospective change in the law.

Conclusion: Notification No. 18/97 dated 10.04.1997 was held to be clarificatory in nature and retrospective in operation, and the Revenue's appeal failed.

Ratio Decidendi: An amendment that substitutes an earlier exemption notification with a later one, without creating a new substantive condition, is clarificatory and operates retrospectively.

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