Strict construction of exemption notifications confined relief to rice bran oil-based product, not mixed vegetable products.

The exemption under Notification No. 61/71, as amended by Notification No. 40/72, applied only to vegetable product made from indigenous rice bran oil in the manner expressly stated in the notification. The phrase "said vegetable product" did not extend the exemption to a mixed admixture of vegetable products made from other oils or til oil. Exemption notifications must be construed strictly on their plain language, and the scope cannot be enlarged by intendment. On that construction, the exemption conditions were not met and the demand was upheld.

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Issues: Whether the exemption under Notification No. 61/71, as amended by Notification No. 40/72, was available on the entire quantity of mixed vegetable product manufactured from hydrogenated rice bran oil and other oils.

Analysis: The notification exempted only such vegetable product as is made from indigenous rice bran oil, subject to the stated conditions. On a plain reading, the benefit was available only where rice bran oil was first converted into vegetable product and that vegetable product was thereafter issued out in admixture with til oil or vegetable product made from other oils, or both. The expression "said vegetable product" in the conditions was held not to extend to the admixture itself. Exemption notifications were required to be construed strictly according to their plain language, and the scope of the notification could not be enlarged by intendment.

Conclusion: The conditions for availing the exemption were not satisfied and the demand was sustainable.

Final Conclusion: The revision failed, and the exemption claim on the mixed product was disallowed.

Ratio Decidendi: An exemption notification must be strictly construed according to its plain wording, and relief is confined to the class of goods and manner of manufacture expressly covered by the notification.

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