Credit notification for ethyl alcohol applies only to the eligible alcohol content of denatured spirit, not the full input

A credit notification referring to ethyl alcohol used in manufacture was interpreted as covering only the ethyl alcohol content of denatured spirit, not the denaturing agent or the entire composite input. The Tribunal relied on an earlier construction of the expression "ethyl alcohol" and found no material to displace that interpretation. The eligible benefit was therefore confined to the identifiable alcohol component alone, and the broader claim on the whole quantity of denatured spirit was rejected.

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Issues: Whether money credit under Notification No. 231/87-C.E. was admissible on the entire quantity of denatured spirit used as input, or only on the ethyl alcohol content contained in that input.

Analysis: The notification granted the benefit with reference to ethyl alcohol used in the manufacture of the specified final products. The dispute turned on whether denatured spirit, which contains ethyl alcohol along with a denaturing agent, could be treated as fully covered by the notification. The Tribunal noted that an earlier decision had already construed the expression "ethyl alcohol" in the notification and had held that the benefit extended only to the ethyl alcohol content of denatured spirit and not to the denaturing ingredient. No material was shown to displace that interpretation.

Conclusion: The benefit of money credit was confined to the ethyl alcohol content of the denatured spirit, and not to the entire input.

Final Conclusion: The appeal failed and the lower appellate order was sustained on the notified benefit being limited to the eligible alcohol content alone.

Ratio Decidendi: Where an exemption or credit notification specifies a particular input, the benefit cannot be extended beyond the identified eligible component of a composite input.

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