Prospective operation of exemption amendments bars retrospective refund claims for clearances made before the change.

Exemption notification benefits are governed by the law in force on the date of each clearance, because each clearance is a separate legal event. An amendment enhancing the eligibility limit will operate prospectively unless the notification clearly states otherwise; here, no retrospective intent was expressed. The claimed application of the amended limit to prior clearances was therefore rejected, and refund entitlement was denied.

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Issues: Whether an amendment enhancing the eligibility limit in an exemption notification could be applied retrospectively to clearances made before the amendment so as to confer refund entitlement.

Analysis: The benefit of an exemption notification is governed by the law in force at the time of clearance. Each clearance is a separate legal event, and the assessee's entitlement must be tested against the notification as it stood on that date. The amending notification contained no indication that the enhanced limit was to operate retrospectively. Applying the amendment to prior clearances would produce anomalous results and is contrary to the settled rule that exemption amendments operate prospectively unless the instrument clearly provides otherwise.

Conclusion: The assessee was not entitled to the benefit of the amended notification for clearances made before the amendment. The retrospective application claimed was rejected and the relief was denied.

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