Exemption notification must be read on its own terms; prior tariff classification ruling could not deny benefit for machinery parts.

Exemption under Notification No. 06/2011-CE had to be tested on the notification's own language, not by mechanically applying a prior tariff-classification ruling. The Revenue did not dispute the appellant's tariff classification, and the goods were described on admitted facts as parts or components of the specified machinery. On that basis, the exemption could not be denied, the demand was unsustainable, and penalty could not be imposed. The impugned orders were set aside and relief followed.

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Issues: Whether the goods manufactured by the appellant were entitled to exemption under Notification No. 06/2011-CE as parts or components of the machinery specified in the notification, and whether denial of the benefit could be sustained on the basis of the earlier classification decision relied upon by the Revenue.

Analysis: The appellant's product classification under the relevant tariff heading was not disputed by the Revenue. The dispute was confined to entitlement under the exemption notification. The earlier decision relied upon by the Revenue was rendered in a classification context, whereas exemption notifications are construed on their own language and not by applying the same interpretative approach as tariff classification. Since the notification granted benefit to parts or components of the specified machinery, and the appellant's goods fell within that description on the admitted facts, the benefit could not be denied on the basis urged by the Revenue.

Conclusion: The appellant was entitled to the benefit of the exemption notification, the demand was not sustainable, and penalty was not imposable.

Final Conclusion: The impugned orders were set aside and the appeals were allowed with consequential relief.

Ratio Decidendi: Where exemption is granted to parts or components of specified machinery, the eligibility must be tested on the language of the notification itself, and a prior decision rendered in a tariff classification dispute cannot be mechanically applied to deny exemption when the relevant classification is undisputed.

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