Exemption notifications may be restricted by later amendment, and clarifying classifications need not conflict with the tariff item.

The power to grant an exemption from duty under Rule 8 includes the power to restrict, modify, or amend that exemption by later notification. A clarifying explanation defining flexible and rigid plastic sheets was treated as a valid limitation on the exemption, confining relief to flexible sheets only. That clarification did not conflict with Tariff Item 15A, because the tariff continued to cover both categories for duty purposes while the notification determined which goods received exemption. The amended exemption notification was therefore upheld, and the challenge failed.

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Issues: Whether the Central Government could validly amend the exemption notification issued under Rule 8 of the Central Excise Rules, 1944 by inserting an explanation defining "flexible" and "rigid" plastic sheets, and whether the amended notification was inconsistent with Tariff Item 15A of the First Schedule to the Central Excises and Salt Act, 1944.

Analysis: Exemption from duty is a concession and not a vested right of the manufacturer. The power to grant exemption under Rule 8 includes the power to restrict, modify, or amend the exemption by notification, and the Central Government could have introduced the explanatory definition even at the time of the original notification. The added explanation merely clarified the scope of the exemption by distinguishing flexible from rigid plastic sheets so that the exemption remained confined to flexible plastic sheets. Such classification did not conflict with Tariff Item 15A, which continued to cover both flexible and rigid plastic sheets for duty purposes; the explanation only determined which of those goods would receive the exemption.

Conclusion: The amendment notification was valid and was not inconsistent with Tariff Item 15A; the challenge to the notification failed.

Final Conclusion: The exemption as restricted by the amended notification stood upheld, and the assessee was not entitled to the benefit of the quashed exemption.

Ratio Decidendi: The Government's power to grant exemption from duty by notification includes the power to amend or restrict that exemption by a later notification, and a clarification that limits exemption to a defined class of goods does not conflict with the tariff item under which those goods are otherwise dutiable.

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