Retrospective effect in exemption notifications cannot be presumed, and excise liability cannot be created by reinterpreting distinct expressions.

An exemption notification under Rule 8(1) of the Central Excise Rules, 1944 was applied on the basis of the actual "rubber component" in the goods, and the authorities had already granted exemption on that footing. The later superseding notification did not state that it was retrospective or corrective, so it could not be used to create excise liability for removals made during the earlier notification period. Treating "rubber component" as equivalent to "rubber compound" was therefore unsustainable, and the demand based on that reinterpretation was set aside.

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Issues: Whether the expression "rubber component" in the exemption notification issued under Rule 8(1) of the Central Excise Rules, 1944, could be treated as equivalent to "rubber compound" so as to sustain the excise demand for the period when the earlier notification was in force.

Analysis: The exemption operated on the basis of the actual "rubber component" in the goods, and the authorities had already applied that criterion when granting exemption. The later notification superseding the earlier one did not state that it was retrospective or corrective, and therefore could not be used to impose liability for removals made during the period when the earlier notification applied. The demand based on equating two distinct expressions in the notification was held to be unsustainable.

Conclusion: The demand and the appellate orders were set aside, and the petition was allowed.

Ratio Decidendi: A superseding exemption notification does not operate retrospectively in the absence of express language, and an erroneous expression in an exemption notification cannot be reinterpreted to impose excise liability for transactions covered by the earlier notification.

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