Rebate computation under cotton seed oil notification requires total goods cleared in the period, including batches without the input.

For rebate under Notification No. 23/75 on cotton seed oil used in manufacturing vegetable products, the relevant base for calculating the input-use percentage was the total quantity of vegetable product cleared during the prescribed period. Batches manufactured without cotton seed oil were not to be excluded unless the notification expressly required such exclusion. The construction of the notification's text, table and main body therefore required inclusion of all vegetable products cleared in the period, and the contrary assessee position was rejected.

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Issues: Whether, for computing the rebate under Notification No. 23/75 dated 1-3-1975 on the use of cotton seed oil in the manufacture of vegetable products, the total weight of the vegetable product had to include all vegetable products cleared during the relevant period, including batches manufactured without cotton seed oil.

Analysis: The expression in the notification was read with its table and the main body of the notification. On that reading, the relevant base for determining the percentage of cotton seed oil use was the total quantity of vegetable product cleared during the prescribed period. The exclusion of batches manufactured without cotton seed oil was not supported by the language of the notification.

Conclusion: The total weight for rebate calculation had to include the entire quantity of vegetable product cleared during the relevant period, irrespective of whether a particular batch contained cotton seed oil. The assessee's contention was rejected and the departmental view was upheld.

Ratio Decidendi: Where a rebate notification measures eligibility by reference to the total weight of goods cleared during a period, that total includes all goods cleared in the period unless the notification expressly directs exclusion of goods manufactured without the relevant input.

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