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Issues: Whether money credit under Rule 57K read with Notification No. 45/89-C.E. (N.T.) was admissible on the quantity of raw oil taken for processing or only on the quantity of oil or fat actually subjected to hydrogenation.
Analysis: Rule 57K enables money credit only as notified by the Central Government and makes the concession subject to the terms of the notification. Notification No. 45/89-C.E. (N.T.) specifically confines credit to the quantity of oil or fat subjected to hydrogenation in the manufacture of vanaspati and bakery shortening, and not to the entire quantity of raw oil taken into processing. The notification was treated as a machinery provision fixing the extent of the concession, and such a limitation was held permissible. The interpretation was also supported by the earlier Tribunal decision in the appellant's own case and by the principle that the notification must be construed to give effect to its purpose.
Conclusion: Credit is admissible only on the quantity actually subjected to hydrogenation, not on the quantity of raw oil taken for processing. The appellants' claim was therefore rejected.
Ratio Decidendi: Where a money credit notification issued under Rule 57K expressly limits the concession to the quantity of oil or fat subjected to the specified process, the benefit cannot be extended to the larger quantity of raw material taken for preliminary processing.