Strict construction of exemption notifications denies relief for speciality oils outside the notification's express terms.

An exemption notification for speciality oils was construed strictly: only preparations made by blending or compounding mineral oil with other oils or substances fell within its terms. The notification's explanation and proviso limited the scope of the exemption, so products obtained merely by mixing mineral oils under Chapter 27 could not qualify. The interpretation that expanded the exemption and rendered limiting words redundant was rejected. Prior orders relating to different products did not control the present product. The assessee's claim failed, and the product was held not entitled to exemption.

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Issues: Whether the speciality oil manufactured by blending or compounding of mineral oils was entitled to exemption under Notification No. 287/86-C.E. dated 5 May 1986.

Analysis: The notification exempted only speciality oils that were preparations made by blending or compounding mineral oil with other oils or any other substance. The explanation and proviso showed that not all speciality oils were covered, and that the exemption could not be extended to products obtained merely by mixing mineral oils falling under Chapter 27. The interpretation adopted by the lower authorities was rejected because it ignored the limiting words of the notification and made part of the language redundant. Prior orders concerning different products did not bind the Revenue in relation to the present product.

Conclusion: The product was not entitled to the exemption and the assessee's claim failed.

Ratio Decidendi: An exemption notification must be construed strictly, and only those goods that clearly satisfy its express terms can obtain the benefit; words in the notification cannot be ignored or treated as surplusage.

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