Exemption notification must be read as written: duty-paid pig iron use qualified steel ingots for relief despite mixed materials.

Steel ingots made from scrap obtained by breaking up duty-paid pig iron used in ingot moulds and bottom stools remained entitled to exemption under the excise notification. The notification covered steel ingots in which duty-paid pig iron was used, and its wording did not require that pig iron be used only, entirely, or exclusively. The Court held that the revenue could not add limiting words not found in the text, especially where doing so would effectively tax the same material twice. The assessee's claim to exemption was therefore upheld.

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Issues: Whether steel ingots manufactured from scrap obtained by breaking up duty-paid pig iron used in ingot moulds and bottom stools, and mixed with other non-duty-paid materials, were entitled to exemption under the applicable excise notification.

Analysis: The operative notification exempted steel ingots in which duty-paid pig iron was used. The materials did not lose their character merely because duty-paid pig iron was first converted into ingot moulds and bottom stools, later broken into scrap, and then remelted for making steel ingots. The notification did not use limiting words such as "only", "entirely", or "exclusively", and therefore did not justify denying exemption merely because duty-paid pig iron was used along with other materials. The construction adopted by the revenue would also result in taxing the same article twice, which was not supported by the language of the notification.

Conclusion: The exemption was available, and the assessee's claim succeeded.

Final Conclusion: The revenue authorities were not justified in denying the exemption, and the High Court's decision in favour of the assessee was upheld.

Ratio Decidendi: An exemption notification granting relief where duty-paid pig iron is used must be applied according to its text and cannot be restricted by reading into it a requirement of exclusive or sole use unless the notification expressly says so.

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