Exemption for pharmacopoeial standard citric acid confirmed on admitted facts; end-use question left open for other cases.

Citric acid that was undisputedly a pharmacopoeial standard acid and a product of drug, drug intermediate or pharmaceutical character fell within the exemption notifications on the admitted facts. The Department did not dispute that factual position, so entitlement followed without needing to examine end-use. The Court left open the broader question whether end-use is relevant in other cases when deciding similar notification benefits.

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Issues: Whether citric acid manufactured by the respondents was entitled to the benefit of the exemption notifications, and whether the question of end-use arose where the product was admittedly a pharmacopoeial standard acid and drug intermediate.

Analysis: The factual position that the manufactured citric acid was a pharmacopoeial standard acid and a product of drug, drug intermediate or pharmaceutical character was not disputed by the Department. On that admitted position, the product fell within the benefit of the notifications, and there was no occasion to examine end-use. The Court expressly left open the broader question whether end-use is relevant for deciding entitlement to the notifications in other cases.

Conclusion: The appeal was without merit on the admitted facts and the assessee was held entitled to the benefit of the notifications.

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