Exemption expiry under Notification No. 34/83: amended notification limited the benefit to 30-6-1986, ending post-date relief.

Notification No. 34/83 exempted the value of metal containers from the assessable value of packed goods, but Notification No. 191/83 inserted a clause limiting the life of "this Notification" up to 30-6-1986. That phrase was read as referring to Notification No. 34/83 as amended, not merely to the amending notification itself. The exemption therefore expired on 30-6-1986 and was not available thereafter; the lower authorities' view was upheld.

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Issues: Whether the exemption under Notification No. 34/83 continued to apply after 30-6-1986 despite the amendment by Notification No. 191/83.

Analysis: Notification No. 34/83 originally exempted the value of metal containers from the assessable value of the packed goods. Notification No. 191/83 amended the earlier notification by inserting an additional clause stating that "this Notification" would remain in force up to and inclusive of 30-6-1986. The expression "this Notification" was construed to refer to Notification No. 34/83 as amended, and not merely to the amending Notification No. 191/83. On that reading, the exemption had a limited life and expired on 30-6-1986.

Conclusion: The exemption was not available after 30-6-1986 and the view of the lower authorities was upheld.

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