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Issues: Whether rebate under Rule 12 of the Central Excise Rules extends to duty paid on raw materials or inputs used in the manufacture of exported final products.
Analysis: Rule 12 was applied only to the duty paid on the goods actually exported. The reasoning distinguished Rule 12 from the scheme of export under bond and held that the definition of goods in Rule 13 could not be carried into Rule 12. The existence of Rule 12A, which specifically deals with rebate in respect of excisable material used in the manufacture of exported goods, showed that Rule 12 was not intended to cover inputs. The claim for rebate on forgings used in manufacture was therefore outside the scope of Rule 12.
Conclusion: Rebate under Rule 12 is not available on duty paid on raw materials or inputs used in the manufacture of exported goods, and the claim fails.
Ratio Decidendi: A rebate provision limited to exported goods cannot be extended to duty paid on inputs used in their manufacture where the rules separately provide for such relief elsewhere.