Plain language of exemption notifications governs deemed credit claims; Grey Cotton Fabrics was not treated as an input.

Grey Cotton Fabrics was held not to qualify as an input for deemed credit under Notification No. 29/96-C.E. (N.T.) because the notification's plain wording did not mention it. The CESTAT applied the principle that no word can be added to or read into a notification beyond its express terms, and on that basis declined the deemed credit claim at the stay stage. The applicant was directed to make a pre-deposit, while stay from penalty and interest was kept in abeyance on compliance.

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Issues: Whether Grey Cotton Fabrics was covered as an input under Notification No. 29/96-C.E. (N.T.) dated 03.09.1996 for availing deemed credit on Processed Cotton Fabrics.

Analysis: The Notification was examined on its own language, and Grey Cotton Fabrics was found not to be mentioned as an input. On that basis, the claim for deemed credit was not accepted at the stay stage. The reasoning proceeded on the principle that words cannot be added to or imported into a notification beyond its express terms.

Conclusion: The issue was decided against the appellant and in favour of the Revenue, and the applicant was directed to make a pre-deposit of Rs. 1.8 lakh while stay from penalty and interest was kept in abeyance upon such deposit.

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