Exemption for alloy steel forgings applies where the notification excludes only stainless steel and no express exclusion covers other alloy steel.

Forgings and forged articles of alloy steel fell within the exemption under Notification No. 223/88-CE because the term "steel" in Chapter 72 was read broadly to include other alloy steel. The notification expressly excluded only stainless steel, and that exclusion could not be extended by implication to alloy steel. As the goods were not shown to be stainless steel, the exemption applied and the Revenue's challenge failed.

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Issues: Whether forgings and forged articles of alloy steel were entitled to exemption under Notification No. 223/88-CE, which extended concessional duty to forgings and forged articles of steel other than stainless steel.

Analysis: The exemption was denied on the premise that alloy steel was distinct from steel. The Tribunal relied on the interpretation already adopted in earlier precedent that the expression "steel" in Chapter 72 of the Central Excise Tariff Act, 1985 was wide enough to cover different kinds of steel, including other alloy steel. The notification specifically excluded stainless steel, but did not exclude other alloy steel. Since the goods were not shown to be stainless steel, the exclusion could not be extended by implication.

Conclusion: The forgings and forged articles of alloy steel were eligible for the exemption under Notification No. 223/88-CE, and the Revenue's challenge failed.

Ratio Decidendi: Where an exemption notification covers forgings of steel and specifically excludes only stainless steel, goods of other alloy steel fall within the exemption unless expressly excluded.

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