Exemption notifications import procedure only when expressly stated; substantive Rule 56A restrictions cannot be read in by implication.

An exemption notification that expressly incorporates only the procedure in Rule 56A of the Central Excise Rules does not also import later substantive restrictions into that notification. The revenue's reliance on the amended rule could not defeat the exemption, because the notification had adopted only the procedural mechanism and not the substantive credit-disallowance provision. Reading the restriction into the notification would have undermined its purpose and made the exemption ineffective. The governing principle is that substantive limits are not implied into an exemption notification unless they are expressly included; on that basis, entitlement to the exemption was upheld.

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Issues: Whether, for availing the exemption under Notification No. 103/61, only the procedure in Rule 56A of the Central Excise Rules, 1944 was required to be followed or the substantive restrictions introduced in Rule 56A also applied.

Analysis: Notification No. 103/61, as amended, expressly required compliance only with the procedure set out in Rule 56A. The amendment to Rule 56A relied upon by the revenue had withdrawn credit in certain cases, but that substantive change could not be imported into the exemption notification when the Central Government had chosen to incorporate only the procedural mechanism. Reading the amended substantive restriction into the notification would make the exemption redundant and defeat its object.

Conclusion: The substantive provisions of Rule 56A did not govern entitlement under Notification No. 103/61; only the procedural requirements applied, and the assessee was entitled to the exemption.

Ratio Decidendi: Where an exemption notification incorporates only the procedure of a statutory rule, its substantive restrictions cannot be read into the notification unless expressly provided.

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