LPG exemption from Special Additional Duty upheld where notification and circular covered bulk imports regardless of consumer end use.

Liquefied petroleum gas imported in bulk and supplied to domestic and other consumers was treated as eligible for exemption from Special Additional Duty under Notification No. 20/2006-Cus. The notification covered petroleum gases under Chapter 27, and the relevant Board circular clarified that LPG fell within the exemption regardless of the category of consumer or end use. The operative point was that the exemption wording was broad enough to include LPG without any tariff distinction based on consumption pattern, so the Revenue's objection to exemption failed.

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Issues: Whether liquefied petroleum gas imported in bulk and supplied to domestic as well as other consumers was eligible for exemption from Special Additional Duty under Notification No. 20/2006-Cus dated 01.03.2006.

Analysis: The notification referred to petroleum gases falling under Chapter 27, and the relevant Board circular clarified that liquefied petroleum gas, whether supplied to domestic consumers or to other categories of consumers, was covered by the exemption. The circular further explained that there was no tariff distinction in the treatment of LPG based on end use for the purpose of this exemption, and that the wording of the notification was broad enough to include LPG irrespective of use.

Conclusion: The LPG import was entitled to exemption from Special Additional Duty, and the Revenue's challenge to the grant of exemption failed.

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