Exemption for goods used within the same factory applies where the notification does not expressly add further-use restrictions.

Notification No. 118/75 exempted goods falling under Tariff Item 68 when manufactured in a factory and intended for use in that same factory. The notification did not confine the benefit to goods used only in further manufacture of another product, and no such restriction could be implied where it was not expressly stated. On that construction, the goods were covered by the exemption, the demand was unsustainable, and the appeals succeeded with consequential relief granted to the extent permissible.

---

---

Issues: Whether the goods manufactured in the factory were entitled to exemption under Notification No. 118/75 when intended for use within the same factory.

Analysis: Notification No. 118/75 exempted goods falling under Tariff Item 68 when manufactured in a factory and intended for use in that factory. The notification excluded only complete machinery manufactured in the factory and did not limit the exemption by requiring the goods to be used in further manufacture of another product. On the plain language of the notification, read in the light of the Supreme Court's interpretation, the manufactured goods were covered by the exemption.

Conclusion: The exemption was available and the demand could not be sustained.

Final Conclusion: The appeals succeeded and the impugned orders were set aside with consequential relief to the extent permissible.

Ratio Decidendi: Where an exemption notification grants relief to goods manufactured in a factory for use in that same factory, the benefit cannot be denied by adding a restriction that the goods must be used only in further manufacture of another product unless such restriction is expressly provided.

---