Strict construction of exemption notification defeated ambulance duty relief where registration condition was not satisfied.

Exemption under Notification No. 4/97-C.E. was construed strictly, and the claim failed because the prescribed registration condition for the ambulances was not shown to be satisfied. The later inclusion of one beneficiary in the notification did not cure the defect for the relevant period. The exemption and refund claim was therefore not allowable.

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Issues: Whether exemption under Notification No. 4/97-C.E. dated 01.03.1997 was available for the ambulances in question.

Analysis: The exemption notification was held to be subject to strict construction. The conditions attached to the notification were not satisfied, as the ambulances were not shown to have been registered in the manner required by the notification. The subsequent inclusion of one beneficiary in the notification could not assist the claim for the material period.

Conclusion: The exemption claim for the ambulances was not allowable and the rejection of the refund/exemption claim was upheld.

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