RG-1 register basis governed sugar rebate, so brown sugar counted in the original season despite later reprocessing.

The notification required rebate computation to be based on the quantity of sugar shown in the RG-1 register, so brown sugar entered in the 1982-83 season had to be treated as production of that season even though it was reprocessed later. Because the notification prescribed the method for determining eligible sugar production, the authorities could not exclude the brown sugar by applying any different basis. The rejection of the rebate claim was therefore incorrect, and the assessee was entitled to have the brown sugar counted for the 1982-83 season.

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Issues: Whether brown sugar produced in one sugar season but reprocessed in the subsequent season was to be treated as production of the season in which it was originally produced for the purpose of computing excess sugar production rebate under the relevant notification.

Analysis: The relevant notification provided that, for calculating rebate, the quantity of sugar shown in the RG-1 register was to be taken into account. Since the brown sugar had been entered in the RG-1 register in the 1982-83 season, the method of computation had to follow the notification itself. The notification prescribed a specific basis for determining sugar produced, leaving no alternative method for excluding the brown sugar merely because it was reprocessed in the later season. The lower authorities did not apply the notified method correctly while computing the quantity of sugar eligible for rebate.

Conclusion: The assessee was entitled to have the brown sugar counted for the 1982-83 season, and the rejection of the rebate claim was incorrect.

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