Plain language controls exemption claims for LPG supply; certificate and circular cannot override statutory conditions.

An exemption entry for LPG applied only to gas supplied in cylinders containing up to 14.5 kg for domestic use, and the plain wording could not be narrowed or expanded by reference to a certificate or trade circular. Although the dealer manufactured LPG and supplied it to HPCL, the filling and supply to end consumers were carried out by HPCL, so the dealer did not establish that it itself supplied LPG in the manner required by the exemption. The Tribunal's interpretation was held to be plausible and not perverse, and no substantial question of law arose. The dealer therefore was not entitled to the exemption.

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Issues: Whether LPG manufactured by the dealer and supplied to HPCL qualified for exemption under the relevant Schedule entry for LPG supplied in cylinders containing up to 14.5 kg for domestic use, and whether the HPCL certificate and trade circular could alter the interpretation of that entry.

Analysis: The relevant Schedule entry, applicable for the period in question, granted nil rate only to LPG supplied in cylinders containing up to 14.5 kg for domestic use. The wording of the entry could not be truncated by ignoring the express requirement as to cylinder capacity. The dealer manufactured LPG and supplied it to HPCL, while HPCL undertook the filling and supply to end consumers. The record did not establish that the dealer itself supplied LPG in the manner contemplated by the exemption. A trade circular could not control or override the plain language of the Schedule entry, and the HPCL certificate did not create eligibility where the statutory conditions were not met. The Tribunal's view was a possible and plausible one and did not suffer from perversity or an error of law giving rise to a substantial question of law.

Conclusion: The dealer was not entitled to the exemption, and the challenge to the Tribunal's decision failed.

Ratio Decidendi: An exemption entry must be applied according to its plain statutory conditions, and a certificate or circular cannot enlarge the scope of the exemption where the claimant does not satisfy those conditions.

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