Exemption notification for cast articles construed in favour of assessee where duty paid pig iron was used as raw material.

Exemption under Notification No. 74/62 was treated as available for C.I. cast articles manufactured from duty paid pig iron, because the notification did not expressly confine the raw material to old iron or steel scrap. The Tribunal applied the established interpretive approach that ambiguity in an exemption provision must be resolved in favour of the assessee. On that basis, the final products were regarded as within the scope of the notification and exemption was allowed.

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Issues: Whether the appellants were entitled to exemption under Notification No. 74/62 dated 24-4-1962 for C.I. cast articles manufactured using duty paid pig iron.

Analysis: The exemption notification was held applicable where the final products were manufactured from duty paid pig iron. The Tribunal followed its earlier view and the related judicial approach that, where the notification did not expressly restrict the raw material to old iron or steel scrap alone, any ambiguity in the exemption provision had to be resolved in favour of the assessee.

Conclusion: The appellants were held entitled to claim exemption under Notification No. 74/62.

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