Exemption notifications apply to the expressly defined qualifying period, not merely the date of issue.

Notification No. 193/82-C.E. is explained as granting exemption for the entire production during May to September, 1982 where production in the corresponding months of the preceding three sugar years was nil. The key interpretive point is that the qualifying period is fixed by the notification's express wording, so the benefit cannot be curtailed merely because the notification was issued later. The Tribunal's restriction of exemption from 11-6-1982 onwards is described as inconsistent with paragraph 4, which ties eligibility to the stated May-to-September period.

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Issues: Whether the appellant was entitled to exemption under Notification No. 193/82-C.E. for the entire period from 1-5-1982 to 30-9-1982, where the notification itself stated that the entire production during May to September, 1982 would qualify if production during May to September in the preceding three sugar years was nil.

Analysis: Notification No. 193/82-C.E. amended the earlier exemption scheme and expressly provided that where production during May to September in all the preceding three sugar years was nil, the entire production during May to September, 1982 would be entitled to exemption. The Tribunal restricted the benefit only from 11-6-1982 onwards merely because that was the date of the later notification. That approach was inconsistent with the language of paragraph 4, which fixed the exempted period by reference to May to September, 1982, and not by reference to the date of issue of the notification.

Conclusion: The appellant was entitled to the exemption for the whole period 1-5-1982 to 30-9-1982.

Ratio Decidendi: Where an exemption notification expressly defines the qualifying period of benefit, the exemption must be applied according to that express period and not curtailed merely because the notification was issued on a later date.

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