Concessional duty under Notification No. 99/81-C.E. must be computed on a consolidated basis, not year by year.

Concessional duty under Notification No. 99/81-C.E. was to be computed on the basis of the notification as a whole, not by splitting production year by year. The language extending the benefit to sugar produced from the 1981 sugar year onwards did not require year-wise compartmentalisation for calculating the eligible free-sale quota or the concessional benefit. The computation had to follow the wording of the notification rather than the department's intended interpretation. The assessee was therefore entitled to consolidated treatment as directed by the Collector (Appeals), and the Revenue's challenge failed.

---

---

Issues: Whether the concessional duty under Notification No. 99/81-C.E. was to be computed separately for each year of production or on the basis of the entire period covered by the notification.

Analysis: The notification extended concessional duty to sugar produced from the sugar year 1981 and thereafter. Its language did not require year-wise compartmentalisation of production for computing the eligible free-sale quota or the concessional benefit. The computation had to follow the words used in the notification, and not an approach based on the department's intended reading.

Conclusion: The benefit of the notification was not required to be computed separately for each year; the assessee was entitled to the consolidated treatment directed by the Collector (Appeals), and the Revenue's appeal failed.

---