Exemption notification interpretation sustained for imported goods; amended conditions did not justify interference with the benefit granted.

Amended exemption notifications were construed as imposing, and then relaxing, conditions on duty payment on inputs and non-availment of credit in manufacture. The Tribunal treated the earlier judicial view on the exemption notification as continuing and noted that the appellate authority had already considered the relevant Supreme Court ruling along with the amended notifications. It also relied on its own final orders in identical disputes between the same parties, which had attained finality. On that basis, the Tribunal upheld the assessee's entitlement to the exemption benefit for the imported goods and found no reason to interfere with the impugned orders.

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Issues: Whether the amended exemption notifications applied to imported goods so as to sustain the assessee's claim for benefit, and whether the impugned orders granting such benefit called for interference.

Analysis: The amendments introduced by Notification No. 34/2015 and Notification No. 37/2015 were understood to impose and then relax conditions concerning duty payment on inputs and non-availment of credit in manufacture. The earlier judicial view on the exemption notification was treated as continuing in force, and the Tribunal noted that the Commissioner (Appeals) had already considered the relevant Supreme Court ruling together with the amended notifications. The Tribunal also relied on its own earlier final orders in identical matters between the parties, and held that those orders had attained finality.

Conclusion: The Tribunal upheld the assessee's entitlement to the benefit of the exemption notification as applied to the imported goods, and found no reason to interfere with the orders appealed against.

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