Exemption for raw naphtha used in fertilizer and ammonia manufacture upheld by applying earlier Tribunal ratio

Entitlement to exemption under Notification No. 75/84-C.E. for raw naphtha used in manufacturing fertilizer and ammonia was treated as governed by an earlier Tribunal order in the same assessee's case. The Tribunal found the issue identical to the one already decided and applied that ratio to the present facts without fresh merits re-adjudication. On that basis, the exemption was held admissible.

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Issues: Whether the appellants were entitled to exemption under Notification No. 75/84-C.E. in respect of raw-naphtha received and used in the manufacture of fertilizer and ammonia.

Analysis: The issue was treated as already settled by an earlier order of the Tribunal in the appellants' own case. The Tribunal found that the earlier decision had decided an identical issue and that its ratio applied to the facts of the present appeal. On that basis, the Tribunal followed the earlier ratio without independently re-adjudicating the merits.

Conclusion: The exemption was held admissible to the appellants.

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