Exemption notification sequence must follow express wording, so earlier input-duty credit applies before later exemption.

An exemption notification must be construed according to its express language, and where it states that it operates read with an earlier notification then the earlier input-duty credit exemption must be applied first, with the later exemption worked out only afterwards. The Court distinguished valuation authority because it concerned assessable value, not the sequence for applying exemption notifications. It also rejected the argument that such construction caused impermissible double taxation, holding that clear notification language controls. The Tribunal's view on the order of application was affirmed and the assessee's contrary contention failed.

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Issues: Whether the exemption under the notification dated 16 June 1977 granting credit for duty paid on inputs had to be applied before the exemption under the notification dated 14 July 1978, or whether the latter notification was to be applied first.

Analysis: The notifications were construed according to their language. The notification dated 14 July 1978 expressly operated "read with any relevant notification issued under the said sub-rule (1) of Rule 8 and in force for the time being", showing that the earlier input-duty exemption notification had to be given effect first. The reliance on the assessable value case was distinguished because it dealt with valuation, not the sequence in which exemption notifications were to be applied. The contention based on supposed double taxation was also rejected because no general rule barred such a result where the notification language was clear.

Conclusion: The notification granting exemption to the extent of duty already paid on inputs was required to be applied before the notification dated 14 July 1978, and the assessee's contrary contention was rejected.

Final Conclusion: The appeal failed on the construction of the exemption notifications and the Tribunal's view on the sequence of application of the notifications was affirmed.

Ratio Decidendi: Where an exemption notification expressly provides that it operates read with an earlier notification in force, the earlier notification must be applied first and the later exemption is worked out only thereafter.

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