Strict construction of exemption notifications governs interpretation of "brought in connection with" in capital goods exemption claims.

An exemption notification must be construed strictly on its own language, and its scope cannot be enlarged by substituting or stretching words not used in the instrument. The note explains that the phrase "brought in connection with" in Notification No. 1/95-C.E. was to be given its plain meaning, rather than read as equivalent to "used in or in relation to" manufacture. On that construction, capital goods received by a 100% export oriented unit without payment of duty were treated as eligible for the exemption, and the departmental challenge failed.

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Issues: Whether capital goods received by a 100% export oriented unit without payment of duty under Notification No. 1/95-C.E. dated 04.01.1995 were eligible for exemption, and whether the expression "brought in connection with" could be read as equivalent to "used in or in relation to" manufacture.

Analysis: The notification used the expression "brought in connection with" and the Court held that this expression had to be given its plain meaning. It rejected the attempt to enlarge the exemption by substituting or stretching the words used in the notification. An exemption notification must be strictly construed, and nothing can be added to or deleted from it so as to alter the legislative intent.

Conclusion: The capital goods fell within the exemption under the notification, and the assessee was entitled to the benefit claimed.

Final Conclusion: The departmental challenge failed because the exemption notification was construed strictly in favour of the recipient of the goods.

Ratio Decidendi: An exemption notification must be construed strictly according to its own language, and its scope cannot be enlarged by reading into it words or meanings not employed by the issuing authority.

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