Exemption for paper clearances upheld where manufacturing-unit findings were factual and no question of law arose.

The exemption claim for the first clearances of 3,500 metric tonnes of paper under Notification No. 6/2000-CE depended on whether the two paper units met the notification conditions. The SC treated the record findings that both units were capable of manufacturing paper from pulp to finished paper, and that the claimed clearances were made from the respective units, as pure findings of fact. Because the revenue did not successfully challenge those findings, the Court held that no question of law arose for interference in appeal, and the assessee remained entitled to the exemption.

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Issues: Whether the assessee was entitled to exemption on the first clearances of 3500 metric tonnes of paper under Notification No. 6/2000-CE, as amended, and whether the finding that the two manufacturing units satisfied the notification conditions gave rise to any question of law.

Analysis: The authorities below had found, as a matter of fact, that both units were equipped to manufacture paper from the stage of pulp to the final stage of paper and that the clearances for which exemption was claimed were made from the individual units. The Court treated these findings as pure findings of fact and noted that the revenue did not successfully put them in issue. On that basis, the impugned order did not disclose any question of law warranting interference in appeal.

Conclusion: The assessee was entitled to the benefit of the exemption, and the revenue's appeal was dismissed.

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