Strict construction of exemption notifications limits relief to expressly mentioned excise duty, excluding additional duty of excise.

Notification No. 214/86-C.E., issued under Rule 8(1) of the Central Excise Rules, 1944, was construed strictly and confined to the duty of excise expressly mentioned in it. Because the notification did not refer to the Additional Duties of Excise (Goods of Special Importance) Act, 1957, its exemption could not be extended by implication to additional duty of excise on goods manufactured on job work. The contextual language of the notification was held insufficient to enlarge the exemption beyond central excise duty, and the Revenue's view was upheld.

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Issues: Whether Notification No. 214/86-C.E. exempted additional duty of excise payable on the goods manufactured on job work.

Analysis: The exemption notification was issued under Rule 8(1) of the Central Excise Rules, 1944 and exempted only duty of excise. The notification did not refer to any other statute extending the exemption to additional duty of excise. In that situation, the expression used in the notification had to be confined to the duty of excise payable under the Central Excise law. Applying the same contextual approach, the exemption could not be enlarged to cover additional duty of excise under the Additional Duties of Excise (Goods of Special Importance) Act, 1957.

Conclusion: The notification did not exempt additional duty of excise, and the Revenue's view was upheld.

Ratio Decidendi: An exemption notification issued simpliciter under Rule 8(1) of the Central Excise Rules, 1944, without reference to the statute levying additional duty, must be construed strictly and confined to the duty expressly mentioned in it.

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