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Issues: Whether the appellant was entitled to exemption under Notification No. 63/95-C.E. for goods supplied as inputs to a unit manufacturing finished goods for the Ministry of Defence, and whether a trade notice or departmental letter issued in relation to a different notification could extend that exemption.
Analysis: The exemption under Notification No. 63/95-C.E. was available only where the goods were manufactured by the specified units and supplied to the Ministry of Defence for official purposes. The notification did not extend to inputs supplied to a manufacturer of finished goods, even if the finished goods were ultimately meant for the Ministry of Defence. A trade notice issued in connection with Notification No. 184/86-C.E. could not be mechanically applied to Notification No. 63/95-C.E. Circulars and departmental instructions are binding only within the scope of the notification for which they are issued, and cannot enlarge the ambit of a different exemption notification. A departmental letter could not override or expand the notification.
Conclusion: The appellant was not entitled to the exemption claimed, and the challenge to the demand failed.
Ratio Decidendi: An exemption notification must be construed according to its own terms, and a circular, trade notice, or departmental letter issued under a different notification cannot be used to expand the scope of that exemption.
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