Exemption notifications must be read by plain words: independent relief under the later notification could not be denied.

Exemption Notification No. 161/66-C.E. was held to operate independently of Notification No. 117/66-C.E. for patent or proprietary medicines under Tariff Item 14E. Because the later notification contained no proviso making its benefit conditional on the earlier notification, and exemption notifications must be construed on their plain words without intendment in taxing statutes, an assessee satisfying the later notification's terms could not be denied relief. The differential duty demand based on refusal of that exemption was therefore unsustainable, and the assessee was entitled to the notification benefit.

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Issues: Whether the assessee was entitled to the benefit of Notification No. 161/66-C.E. independently of Notification No. 117/66-C.E., and whether the differential duty demand based on denial of that benefit was sustainable.

Analysis: The exemption under Notification No. 161/66-C.E. granted relief to patent or proprietary medicines falling under Tariff Item 14E by allowing duty to be calculated after a 25% discount on the price specified in the retail price list. The notifications were treated as independent and not inter-linked, and there was no proviso in the later notification making its operation subject to the earlier notification. Applying the principle that exemption notifications must be construed according to their plain words, and that there is no room for intendment in taxing statutes, the assessee could not be denied the benefit where it satisfied the terms of the later notification.

Conclusion: The assessee was entitled to the benefit of Notification No. 161/66-C.E., and the duty demand confirmed by the lower authorities could not stand.

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