Strict construction of exemption notifications requires every cumulative condition to be met before excise exemption can be claimed.

A public interest exemption notification under the Central Excise Act must be strictly construed, and all stipulated conditions must be satisfied cumulatively before exemption can be claimed. For goods classifiable under Heading 73.10 supplied for defence use, the Tribunal held that the requirements in Serial No. 16 were interdependent, including manufacture by a factory belonging to the Central Government and intended availability or use by a Central Government department. Because the assessee did not satisfy the manufacturing condition, the exemption was denied and the benefit could not be extended by reading the notification's conditions separately.

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Issues: Whether the assessee was entitled to exemption under Notification No. 62/95-C.E. dated 16-3-1995 for goods classifiable under Heading 73.10 supplied for defence use, and whether the notification conditions had to be satisfied cumulatively.

Analysis: The notification was issued under Section 5A of the Central Excise Act, 1944 in furtherance of public interest and the conditions attached to it were held to be interdependent. The description at Serial No. 16 required the goods to satisfy all the stipulated requirements, including manufacture by a factory belonging to the Central Government and intended availability or use by a department of the Central Government. The Tribunal held that the conditions could not be read in isolation and that exemption could not be granted unless the entire bundle of conditions was fulfilled. The assessee did not satisfy the first condition, as the goods were not manufactured by a factory belonging to the Central Government. Reliance on other notifications, Tribunal decisions, and Rule 6(2) of the Cenvat Credit Rules, 2002 was found not to assist the assessee.

Conclusion: The exemption was not available and the denial of benefit was upheld against the assessee.

Ratio Decidendi: A public interest exemption notification must be strictly construed and all its cumulative conditions must be satisfied before exemption can be claimed.

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