Procedural reference to Rule 56A cannot import substantive credit restrictions into an exemption notification.

Notification No. 103/61 granted exemption for synthetic organic dyestuffs made wholly or partly from imported intermediates, and its amendment required only compliance with the procedure under Rule 56A. The substantive restriction in Rule 56A barring credit on certain Tariff Item 68 inputs could not be read into the notification to narrow the exemption, because the reference was procedural and did not adopt Rule 56A's limitations as part of the exemption scheme. The benefit under the notification therefore remained available despite the Rule 56A credit bar, and the contrary view was unsustainable.

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Issues: Whether the restriction in Rule 56A against credit of countervailing duty on Tariff Item 68 inputs could be imported into the exemption granted under Notification No. 103/61, as amended, when the notification required only compliance with the procedure under Rule 56A.

Analysis: The exemption under Notification No. 103/61 granted relief to synthetic organic dyestuffs manufactured wholly or partly out of imported intermediates, and the only limitation introduced by the amending notification was that the procedure under Rule 56A had to be followed. Rule 56A governed the mechanism for availing proforma credit in respect of notified goods and contained its own substantive restrictions, including a bar on credit for certain Tariff Item 68 goods. The crucial distinction was that the assessee was claiming exemption under the notification itself, not the independent credit scheme under Rule 56A. The procedural reference to Rule 56A could govern the mode of claiming and utilising the benefit, but it could not cut down the extent of exemption expressly granted by the notification in the absence of clear language to that effect.

Conclusion: The Tariff Item 68 restriction in Rule 56A did not curtail the exemption available under Notification No. 103/61, as amended. The assessee was entitled to the notification benefit and the contrary order was unsustainable.

Ratio Decidendi: Where an exemption notification incorporates only the procedure under another rule, the procedural machinery cannot be used to import substantive restrictions from that rule so as to diminish the exemption expressly granted by the notification.

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