Exemption notification conditions and lack of financial hardship defeated waiver of pre-deposit in linked customs-excise relief.

An exemption notification must be read as a whole, and its benefit cannot be extended by ignoring express conditions attached to the linked customs exemption. Where the excise exemption was dependent on that customs notification, the conditions governing the customs benefit remained relevant to waiver of pre-deposit. No financial hardship was shown on the facts pleaded, so waiver was not justified and the stay application was rejected.

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Issues: Whether waiver of pre-deposit should be granted on the basis that the excise exemption notification could be read independently of the customs notification conditions, and whether any financial hardship was shown.

Analysis: The exemption under the customs notification was expressly subject to a condition, and the excise exemption was linked to that customs exemption. An exemption notification must be read as a whole, and the benefit cannot be extended by ignoring the conditions attached to it. The appellant also failed to plead any facts showing financial hardship warranting waiver of the deposit.

Conclusion: Waiver of pre-deposit was not justified and the stay application was rejected.

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