Tar exemption extends to pitch creosote mixtures where later notification matches the earlier inclusive tariff entry.

The expression "tar" in the exemption notifications was construed to include partially distilled tars and blends of pitch with creosote oils or other coal tar distillation products. Applying the Supreme Court's earlier inclusive interpretation of the tariff entry, the Tribunal found no material difference in Notification No. 75/84 and treated the same meaning as governing the later notification. On that basis, Pitch Creosote Mixture was held entitled to exemption under the relevant tariff notifications, and the appeals succeeded with consequential relief.

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Issues: Whether Pitch Creosote Mixture was entitled to exemption under the relevant tariff notifications covering tar.

Analysis: The issue was whether the expression "tar" in the exemption notifications covered partially distilled tars and blends of pitch with creosote oils or other coal tar distillation products. The Tribunal noted that the Supreme Court had already construed the inclusive entry in the tariff item to bring such mixtures within the scope of tar, and examined Notification No. 75/84 and found no material difference from the earlier notification considered by the Supreme Court.

Conclusion: The exemption applied to Pitch Creosote Mixture, and the appeals were allowed with consequential relief to the appellants.

Ratio Decidendi: Where a later exemption notification contains no material distinction from an earlier notification already construed by the Supreme Court, the same inclusive tariff meaning governs and the exemption extends to the covered product.

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