Exemption notification to approved project goods cannot be denied by adding a certificate-name not found in the text.

Exemption under Notification No. 108/95-C.E. could not be refused merely because the prescribed certificate was not issued in the assessee's name, where the goods were supplied to an approved project financed by specified international organisations and there was no allegation of diversion. The Court held that the notification contained no express condition requiring the supplier's name to appear on the certificate, and additional restrictions could not be read in by interpretation to defeat the exemption. Exemption notifications must be construed according to their wording, and once the stated conditions are satisfied, the exemption applies. The Revenue's challenge therefore failed, and the appeal was dismissed.

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Issues: Whether exemption under Notification No. 108/95-C.E. dated 28.08.1995 could be denied merely because the certificate was not issued in the assessee's name, where the goods were supplied for approved projects and there was no allegation of diversion.

Analysis: The notification exempts goods supplied to projects financed by specified international organisations and approved by the Government of India, subject to production of the prescribed certificate. The Court held that the notification did not impose any express requirement that the certificate must name the assessee as supplier. The authorities below had rightly noticed that the goods were in fact supplied for the specified project, the requisite certificates were produced, and there was no allegation that the goods were diverted for any other purpose. In such circumstances, no additional condition could be introduced by interpretation to defeat the exemption. The Court also followed the view that exemption notifications must be construed on their wording, without reading in restrictive conditions not found in the text.

Conclusion: The assessee was entitled to the exemption and the Revenue's challenge failed.

Final Conclusion: No substantial question of law arose, and the appeal was dismissed.

Ratio Decidendi: Where the conditions expressly stipulated in an exemption notification are satisfied, exemption cannot be denied by importing an additional requirement not stated in the notification, especially when the goods are shown to have been supplied to the approved project and no diversion is alleged.

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