Aggregate value basis governs exemption ceiling under concessional duty notification; revenue challenge to concessional treatment failed.

Exemption under Notification No. 175/86-CE was to be applied by reference to the aggregate value of clearances, not the quantity of goods cleared. The Tribunal treated the notification's monetary ceiling as the relevant basis for concessional treatment, so duty at the normal rate became payable only on clearances exceeding that value limit. On that interpretation, the revenue challenge to the concessional duty treatment was rejected and the lower authorities' orders were affirmed.

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Issues: Whether the exemption under Notification No. 175/86-CE dated 01.03.1986 was to be applied on the value of clearances and whether the revenue appeal challenging the concessional duty treatment was liable to be rejected.

Analysis: The Tribunal applied the earlier decision holding that the notification grants exemption with reference to the value of goods cleared, not the quantum of goods. On that basis, the total value of clearances was to be adjusted against the monetary limit prescribed by the notification, and duty at the normal rate was payable only on the value exceeding the concessional ceiling.

Conclusion: The revenue challenge was rejected and the orders of the lower authorities were affirmed.

Final Conclusion: The exemption notification operated on an aggregate value basis, so the assessee was entitled to concessional treatment up to the prescribed limit and the appeal failed.

Ratio Decidendi: Where an exemption notification prescribes a monetary ceiling, the concession is to be determined by the value of clearances and not by the quantity of goods cleared.

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