Straight blending of mineral oils qualifies for exemption as speciality or lubricating oils under the notification language.

Straight blending of mineral oils was treated as "blending" for purposes of the exemption notifications, and products manufactured in that manner were found to fall within the descriptions of speciality oils and lubricating oils. Because the notification language did not require blending with any other substance, the products qualified for exemption. The duty demand and penalty were therefore unsustainable.

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Issues: Whether products manufactured by straight blending of mineral oils were entitled to exemption as speciality oils or lubricating oils under the relevant notifications.

Analysis: The dispute turned on the meaning of "blending" in the exemption notifications and whether the products obtained by straight blending of mineral oils satisfied the descriptions of speciality oils and lubricating oils. The Tribunal followed its earlier view that straight blending of mineral oils amounts to blending within the notifications, and that products so manufactured fall within the notified descriptions.

Conclusion: The exemption was held admissible and the duty demand and penalty were unsustainable, in favour of the assessee.

Ratio Decidendi: Products obtained by straight blending of mineral oils are covered by exemption notifications describing speciality oils and lubricating oils where the notification language does not require blending with any other substance.

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