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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether the exemption limit of Rs. 50 lakhs under the relevant notification for institutions certified by the Khadi and Village Industries Commission or Board applied to each individual manufactured product or only to the institution's manufactured turnover in the assessment year.
Analysis: The notification granting exemption was examined in the context of earlier and later notifications. The language of the relevant notification was held to be plain and unambiguous. Where the Legislature intended product-wise exemption, it had said so expressly in earlier notifications. The later notification, however, granted exemption to the institution on its manufactured products up to the stated monetary limit in an assessment year, and did not contain wording showing product-wise limits for each item manufactured. On that text, the Court held that the exemption could not be expanded beyond what was expressly provided.
Conclusion: The exemption limit of Rs. 50 lakhs applied to the institution's manufactured turnover in an assessment year, not separately to each product; the Tribunal's contrary view was unsustainable.
Ratio Decidendi: An exemption notification must be construed according to its plain language, and a monetary exemption limit applies only in the manner expressly stated by the notification.
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