Exemption notifications apply only when all conditions are met; listed goods do not become exempt by entry alone.

Goods listed in an exemption notification are treated as exempted only when all attached conditions are satisfied. Under Notification No. 202 of 1988, exemption depended on compliance with its terms, including the condition that no credit had been taken under the specified credit rules. Because credit had in fact been taken, the goods did not qualify for exemption under that notification. They therefore could not be excluded as exempted goods while computing aggregate clearances under Notification No. 1 of 1993. The decisive principle is that an exemption notification must be applied as a whole, and partial or conditional listing alone does not create exempt status.

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Issues: Whether goods covered by Notification No. 202 of 1988 could be treated as exempted goods for the purpose of computing the aggregate value of clearances under Notification No. 1 of 1993 when the conditions of Notification No. 202 of 1988 were not satisfied and credit had been taken on the inputs.

Analysis: The exclusion in Notification No. 1 of 1993 applied only to goods chargeable to nil rate of duty or goods exempted from the whole of excise duty under another notification. Notification No. 202 of 1988 granted exemption only if its stated conditions were fulfilled, including the requirement that no credit had been taken under the specified credit rules. Once it was admitted that credit had been taken, the respondents were not entitled to the benefit of Notification No. 202 of 1988. Merely being listed in the table to that notification did not make the goods exempted goods unless the notification was satisfied as a whole.

Conclusion: The respondents were not entitled to exclude the value of those goods under Notification No. 1 of 1993 on the strength of Notification No. 202 of 1988; the Revenue's objection on that issue succeeded.

Ratio Decidendi: An exemption notification must be applied in full, and goods are treated as exempted only when every condition attached to the notification is satisfied.

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