Strict construction of exemption notifications confined the benefit to the expressly named tariff item, excluding other unmentioned items.

An exemption notification was construed strictly and confined to the tariff item expressly mentioned in it. Because Notification No. 26/75 referred only to Item 18(i) of the First Schedule to the Central Excises and Salt Act, 1944, it was held not to extend to Item 18(ii), and the claim for automatic exemption was rejected on the plain wording of the notification.

---

---

Issues: Whether Notification No. 26/75 dated 1-3-1975 exempted logically textured yarn spun out of synthetic staple fibres beyond Item No. 18(i) of the First Schedule to the Central Excises and Salt Act, 1944, so as to cover Item No. 18(ii) as well.

Analysis: The notification was read as confined to Item No. 18(i) of the First Schedule to the Central Excises and Salt Act, 1944. Since Item No. 18(ii) was not specifically mentioned, the intention was taken to be that the exemption did not extend to that item. The claim for automatic exemption was therefore rejected on the plain scope of the notification.

Conclusion: The exemption did not cover Item No. 18(ii), and the appeal failed.

Ratio Decidendi: An exemption notification is confined to the tariff item specifically mentioned in it, and a provision not expressly included is excluded from its ambit.

---