Exemption notifications must be read as written: outside-purchased clinker did not bar concessional excise duty.

Cement manufactured with clinker purchased from outside the factory remained eligible for concessional excise duty under Notification No. 154/90-C.E. because the notification itself contained no restriction limiting the benefit to cement made only from in-house clinker. The Tribunal applied the principle that exemption notifications must be interpreted strictly according to their clear terms, and no additional condition can be implied where none is expressed. Distinguishing an earlier notification that did contain an in-factory clinker requirement, it held that the absence of such a qualifying condition was decisive and the exemption could not be denied on the ground that the input was bought externally.

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Issues: Whether the respondents were entitled to concessional excise duty under Notification No. 154/90-C.E. dated 1-11-90 when the cement was manufactured using clinker purchased from outside the factory.

Analysis: The notification governing the dispute contained no condition restricting the benefit to cement manufactured only from clinker produced within the same factory. The Tribunal distinguished the earlier notification relied on by the Revenue, which expressly contained such a restriction. Applying the principle that exemption notifications must be interpreted according to their clear terms and that no additional restriction can be read into them, the Tribunal held that the absence of a qualifying condition was decisive. The cited authorities supported the view that, where the notification does not prohibit use of outside-purchased inputs, the exemption cannot be denied on that ground.

Conclusion: The respondents were entitled to the exemption even though the clinker was purchased from outside, and the Revenue's appeal failed.

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