Specific exemption limits govern specified goods; broader clearance thresholds cannot override the clause for specified goods.

An exemption notification must be construed to give effect to both of its clauses, and a construction that makes the specific limiting clause redundant is impermissible. Where all the goods are specified goods, the clause governing specified goods applies, and the broader clause for excisable goods falling under more than one item does not displace that specific limit. On that reading, an assessee cannot claim refund or exemption by relying on the higher aggregate-clearance limit when the lower limit for specified goods is breached. The operative legal point is that the specific threshold for specified goods controls the exemption analysis.

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Issues: Whether the assessee was entitled to refund/exemption under the notification on the footing that the aggregate value of clearances of the specified goods did not exceed Rs. 20 lakhs, or whether clause (i) of paragraph 2, fixing a limit of Rs. 15 lakhs for specified goods, governed the case.

Analysis: Paragraph 2(i) applies to the aggregate value of clearances of each serial number of the specified goods, while paragraph 2(ii) speaks of excisable goods falling under more than one item. The goods in question were all specified goods. Reading clause (ii) as independent of clause (i) would permit a manufacturer who crossed the Rs. 15 lakhs limit under clause (i) to still claim exemption by relying on the Rs. 20 lakhs limit in clause (ii), which would make clause (i) redundant. The proper construction was that where all items are specified goods, the case falls under clause (i) and not clause (ii).

Conclusion: The assessee was not entitled to exemption or refund on the basis of clause (ii), and the Revenue's contention prevailed.

Ratio Decidendi: An exemption notification must be construed so as to give effect to both its clauses, and a provision cannot be read in a manner that renders a specific limiting clause redundant; where all the goods are specified goods, the specific limit in the clause governing specified goods applies.

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