Exemption for inputs in non-alloy steel ingots and billets denied where the amended notification expressly excluded the final products.

Exemption on inputs used in the manufacture of non-alloy steel ingots and billets was unavailable where the relevant notification, as amended, expressly excluded final products classifiable under sub-headings 7206.90 and 7207.90. The goods in question fell within that excluded category, and the subsequent circular confirmed that the notification benefit did not extend to such cases. On that basis, the exemption claim failed and the demand was sustained.

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Issues: Whether the appellants were entitled to exemption on inputs used in the manufacture of ingots and billets of non-alloy steel under the relevant exemption notification, despite the amendment excluding such final products from its ambit.

Analysis: The exemption notification, on its plain terms, excluded inputs used in the manufacture of ingots and billets of non-alloy steel classifiable under sub-heading 7206.90 and 7207.90. The appellants' goods were admittedly covered by the excluded category. The subsequent circular also clarified that the benefit of the notification was not available in such circumstances.

Conclusion: The appellants were not entitled to the exemption and the demand was /maintained; the appeal failed.

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