Strict construction of exemption notifications excludes waxed corrugated board boxes and cartons from kraft paper exemption.

An exemption notification for corrugated board boxes and cartons made wholly out of Kraft paper was construed strictly, and waxed corrugated board boxes and cartons were held outside its express wording. The addition of the term "waxed" could not enlarge the scope of the notification or bring goods within exemption by interpretation alone. As the goods were not specifically covered by Notification No. 279/82-C.E., the exemption claim failed and the denial of relief was sustained.

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Issues: Whether waxed corrugated board boxes and cartons were covered by Notification No. 279/82-C.E. dated 22-11-1982 granting exemption to corrugated board boxes and corrugated board cartons made wholly out of Kraft paper.

Analysis: The exemption applied only to the goods specifically described in the notification as corrugated board boxes and corrugated board cartons. The addition of the attribute "waxed" would enlarge the scope of the notification beyond its express language. An exemption notification cannot be expanded by interpretation to include goods not clearly covered by its terms.

Conclusion: Waxed corrugated board boxes and cartons were not covered by the exemption notification, and the claim for exemption failed.

Final Conclusion: The denial of exemption was sustained and the appeal was rejected.

Ratio Decidendi: An exemption notification must be construed strictly, and goods not expressly covered by its wording cannot be brought within it by enlarging the scope of the notification.

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