Plain wording of exemption notification governs PU foam and quilted PU foam benefit for coir-industry manufacture.

Notification No. 115/75 was construed on its plain wording to extend exemption to goods manufactured in factories covered by the scheduled industries. A coir-industry unit's PU foam and quilted PU foam qualified for the benefit because the notification did not exclude those intermediary products, and their captively consumed use in making rubberized coir mattresses did not justify a narrower reading. Earlier interpretation of the same notification was followed, reinforcing that exemption cannot be curtailed by implying restrictions not found in the text. The denial of exemption was therefore not sustained.

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Issues: Whether PU foam and quilted PU foam manufactured by a unit engaged in the coir industry were entitled to exemption under Notification No. 115/75.

Analysis: Notification No. 115/75 exempts goods manufactured in factories covered by the industries specified in the Schedule, and the assessee's unit was undisputedly a coir industry. The notification was construed on its plain wording, and the fact that the intermediary products were captively consumed in the manufacture of rubberized coir mattresses did not justify denying the exemption, particularly when the notification did not specifically exclude PU foam or quilted PU foam. The earlier interpretation of the same notification was followed to hold that the benefit cannot be curtailed by reading a narrower restriction into the exemption than the language used.

Conclusion: The intermediary products were held entitled to the exemption under Notification No. 115/75, and the denial of benefit was set aside.

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