Rebate notification must be read strictly: Rule 191B entries cannot enlarge Rule 191A, and estoppel cannot override the statute.

Rebate or refund under Rule 191A of the Central Excise Rules, 1944 had to be confined to the goods specifically covered by the notification issued under that rule. Exported quilt covers were not expressly included, and the entry under Rule 191B could not be imported into Rule 191A because the two rules operated in different fields with separate notified schemes. The claim therefore could not be enlarged by reference to a different rule or by parity with another fiscal arrangement. Promissory estoppel and legitimate expectation also could not override the rule or notification. The result was that rebate/refund was not admissible for quilt covers under Rule 191A.

---

---

Issues: Whether rebate/refund under Rule 191A of the Central Excise Rules, 1944 was admissible for exported quilt covers not expressly covered by the notification issued under that rule, whether the entry under Rule 191B could be read into Rule 191A, and whether promissory estoppel or legitimate expectation could compel grant of rebate.

Analysis: Rule 191A and Rule 191B operated in different fields. Rule 191A governed export of articles on rebate of duty paid on excisable goods used in their manufacture and packing, while Rule 191B dealt with manufacture in bond using duty-unpaid inputs. The notifications issued under the two rules contained different entries, and the fact that some items overlapped did not make the schedules interchangeable. Since the petitioner had proceeded under Rule 191A and the relevant notification covered cotton quilts and not quilt covers, the claim could not be enlarged by borrowing the entry from Rule 191B. Reliance on parity with the scheme considered in the cited Supreme Court decision was misplaced because that case concerned complementary procedures under different rules, not different notified articles. Estoppel and legitimate expectation could not override the governing rule or notification.

Conclusion: Rebate/refund was not admissible under Rule 191A for quilt covers, the Rule 191B entry could not be imported into Rule 191A, and the equitable pleas failed.

Final Conclusion: The writ petition failed on merits because the exported goods were outside the notified coverage of Rule 191A and no equitable doctrine could confer a benefit contrary to the rule.

Ratio Decidendi: A rebate or exemption notification must be construed according to its own terms, and an entry under one distinct fiscal scheme cannot be imported into another to enlarge the benefit; estoppel cannot operate against the statute.

---