Exemption notification for taxi vehicles must be read literally; limited-period registration cannot be used to deny refund.

An exemption notification granting concessional excise duty for motor vehicles registered for use solely as taxis had to be read according to its express terms, and no minimum or permanent period of registration could be implied. Applying the earlier precedent on the predecessor notification, CESTAT held that limited-period taxi registration did not amount to non-compliance with Notification No. 6/2006-CE. The rejection of the refund claim on that ground was therefore unsustainable, and consequential relief followed in favour of the assessee.

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Issues: Whether refund under Notification No. 6/2006-CE could be denied on the ground that the vehicles were registered as taxis for a limited period and not for permanent registration.

Analysis: The notification granted concessional excise duty to motor vehicles after clearance if they were registered for use solely as taxis. The condition in the notification did not prescribe any minimum or permanent period of registration. A restriction could not be imported by implication when the text of the exemption was plain. The earlier precedent on the predecessor notification was applied, and the fact that the registration was for a limited period did not show non-compliance with the notification.

Conclusion: The refund claim could not be rejected on the ground of limited taxi registration. The issue is decided in favour of the assessee.

Final Conclusion: The rejection of refund was unsustainable and the appeals succeeded with consequential relief.

Ratio Decidendi: An exemption notification must be construed according to its express terms, and a condition not stated in the notification cannot be read into it to deny concessional duty or refund.

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