Retrospective exemption denied where notification lacked express language extending its effect to an earlier date.

Exemption notifications operate from the date they are issued unless the text expressly gives retrospective effect. Notification No. 25/97-C.E. was read as applying only from 07.05.1997 because it contained no language extending the exemption back to 01.03.1997. The notification had to be construed as written, and no words could be added to create an earlier effective date. The refund claim based on alleged retrospective operation therefore failed.

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Issues: Whether Notification No. 25/97-C.E. dated 07.05.1997 granting exemption to the goods could be treated as retrospective from 01.03.1997 so as to justify refund of duty paid earlier.

Analysis: The exemption notification was held to operate only from the date on which it was issued. There was nothing in the notification to indicate that the exemption was intended to take effect from an earlier date. The notification had to be read as it stood, and no words could be added to confer retrospective operation in the absence of express language to that effect.

Conclusion: The exemption was not retrospective and the refund claim based on an earlier effective date was untenable.

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