Strict construction of exemption notifications barred a second unit from claiming newsprint duty relief without separate notification.

Exemption notifications for Central Excise Duty must be construed strictly, and a unit can claim relief only if it falls squarely within the notified terms. A second manufacturing unit of the same manufacturer could not rely on a notification issued to another unit, because it had not been separately and distinctly notified under the Newsprint Control Order, 1962. Mere similarity in manufacturing activity was insufficient to extend the exemption, and any ambiguity had to be resolved against the assessee. The second unit was therefore not entitled to the exemption, and the Department's appeal succeeded.

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Issues: Whether a second manufacturing unit can claim exemption from Central Excise Duty on the basis of notification granted to a different unit of the same manufacturer, without separate notification under the Newsprint Control Order, 1962.

Analysis: Exemption notifications are to be construed strictly, and a unit seeking exemption must fall squarely within the notified terms. The first unit had been specifically notified as a newsprint mill, but the second unit had not been separately or distinctly notified under Schedule I of the Newsprint Control Order, 1962. Mere identity of manufacturing activity between the two units was insufficient to extend the exemption to the unnotified unit. In case of ambiguity or doubt, the benefit could not be extended to the assessee.

Conclusion: The second unit was not entitled to the exemption, and the Department's appeal succeeded.

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