Strict construction of exemption notifications bars tapioca thippi flour from claiming a benefit limited to tapioca thippi.

Tapioca thippi flour was held not to fall within an exemption granted only for tapioca thippi because the two were treated as commercially distinct commodities. The Tribunal applied strict construction to the exemption notification and relied on the assessee's own records showing supply of tapioca thippi flour. An earlier view extending exemption to kappi did not apply to a separate product such as flour. The exemption claim was therefore rejected for tapioca thippi flour, confirming that only the specifically named commodity can claim notification benefit.

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Issues: Whether tapioca thippi flour was covered by the exemption granted for tapioca thippi under the relevant Government Order.

Analysis: The exemption was confined to tapioca thippi. The Tribunal held that tapioca thippi and tapioca thippi flour are different commercial commodities. It also noted that the assessee's own records showed supply of tapioca thippi flour. Exemption notifications must be construed strictly, and the earlier view allowing exemption for kappi did not govern a separate commodity such as flour.

Conclusion: The claim for exemption was not available for tapioca thippi flour and the finding against the assessee was upheld.

Ratio Decidendi: A commodity that is commercially distinct from the article specified in an exemption notification cannot claim the benefit of that notification, and exemption provisions must be strictly construed.

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