Notified goods under Rule 10 exclude inputs, confirming abatement and refund entitlement during the closure period.

Under the first proviso to Rule 10 of the Pan Masala Packing Machine Rules, 2008, the term "goods" was construed contextually to mean notified goods only, not inputs. The provision was read as part of the overall scheme, which separately refers to inputs elsewhere, showing that the general word "goods" was not intended to expand the prohibition beyond notified goods. The later insertion of "notified" before "goods" was treated as clarificatory and consistent with that interpretation. On that basis, the assessee was held entitled to abatement and refund with consequential relief.

---

---

Issues: Whether, under the first proviso to Rule 10 of the Pan Masala Packing Machine Rules, 2008, the expression "goods" in the prohibition against removal during the closure period includes inputs or is confined to notified goods.

Analysis: The rule was read as a whole, and the expression used in the proviso was held to refer to the same class of goods contemplated by the scheme, namely notified goods. The use of the general word "goods" was not treated as extending to inputs, particularly because the statutory scheme elsewhere used the expression "inputs" distinctly. The subsequent amendment inserting the word "notified" before "goods" was treated as clarificatory and as supporting the intended meaning of the proviso.

Conclusion: The expression "goods" in the second part of the first proviso to Rule 10 means notified goods and does not include inputs; the assessee was therefore entitled to abatement and refund with consequential relief.

---