Transitional exemption notification covers the entire month of March 2001 despite later issue, preserving the duty scheme.

A transitional exemption notification governing clearances for March 2001 applied to the full month, including 1 March to 15 March, even though it was issued on 16 March 2001. The notification was construed according to its terms as a beneficial transitional measure meant to preserve the intended duty scheme for the entire month, and a contrary reading would create an anomaly by excluding early-March clearances from that framework. The assessee was therefore liable to duty on clearances exceeding the first Rs. 10 lakhs for March 2001.

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Issues: Whether Notification No. 15/2001 dated 16-03-2001, providing a transitional duty arrangement for clearances made during March 2001, applied to clearances from 01-03-2001 to 15-03-2001 even though it was issued on 16-03-2001.

Analysis: Corrugated boxes became dutiable with effect from 01-03-2001, and the notification was issued as a transitional measure for the whole month of March 2001. Accepting the assessee's plea would create an anomaly by leaving early-March clearances outside the intended concessional framework and would defeat the scheme that allowed nil duty on the first Rs. 10 lakhs of March clearances and duty at the prescribed rate thereafter. The date of issue did not restrict the notification to prospective application alone, because its language covered clearances for the entire month.

Conclusion: The transitional notification applied to clearances from 01-03-2001 to 31-03-2001, and the assessee was liable to duty on the clearances in excess of Rs. 10 lakhs for the whole month of March 2001.

Ratio Decidendi: A beneficial transitional exemption notification expressed to govern clearances for an entire period operates for that period according to its terms, even if issued during the period, where such construction avoids defeating the intended duty scheme.

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