Packing materials as inputs under exemption notification qualified for relief until the later restrictive amendment took effect.

Printed cartons used as normal packing for synthetic detergents fell within Notification No. 201/79, because Item 68 goods used in the manufacture of excisable goods qualified for exemption even when they were not raw materials or component parts of the finished product. The notification used "inputs" only as a reference to Item 68 goods used in manufacture, and the later insertion of "raw materials or component parts" by the 1982 amendment narrowed the earlier scope prospectively. Duty-paid printed cartons were therefore covered by the unamended notification until the amendment took effect.

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Issues: Whether printed cartons used for packing synthetic detergents were "inputs" within Notification No. 201/79 so as to entitle the assessee to partial exemption to the extent of duty paid on such cartons.

Analysis: The notification exempted excisable goods in the manufacture of which Item 68 goods had been used, and the expression "inputs" was used only as a term of reference for such Item 68 goods. On a proper construction of the notification as it stood before amendment, the goods referred to as inputs were required only to be used in the manufacture of the finished excisable goods, and not necessarily as raw materials or component parts forming part of the finished product. The later amendment of 28-2-1982, which expressly introduced the words "raw materials or component parts", was treated as narrowing the scope of the earlier notification and as operating prospectively. Printed cartons used as normal packing for marketable goods were therefore covered by the earlier notification, even though they did not constitute ingredients of the detergent itself.

Conclusion: The assessee was entitled to the benefit of Notification No. 201/79 in respect of duty-paid printed cartons used for packing synthetic detergents, and the exemption continued until the notification was amended by Notification No. 105/82.

Ratio Decidendi: Under Notification No. 201/79, Item 68 goods used in the manufacture of excisable goods qualified for exemption even if they were used only as normal packing materials and not as raw materials or component parts of the finished product; the restrictive amendment was prospective.

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