Commercially interchangeable oils qualify as one commodity for exemption, but only certified quantities receive relief.

Mustard oil and rapeseed oil were treated as the same commodity for purposes of the exemption notification because the relevant tariff entry and notification recognized them as commercially interchangeable and part of one class of fixed vegetable oil. The exemption was available only where the prescribed certificate from the designated authority was produced, so the certified quantity qualified for relief. The balance quantity, for which no certificate was produced and no claim was pressed, did not qualify for exemption and the demand survived to that extent.

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Issues: Whether mustard oil and rapeseed oil were to be treated as the same commodity for the purpose of exemption under the notification, and whether the exemption could be denied for quantities for which the prescribed certificate was produced or not produced.

Analysis: The notification in question required production of a certificate from the designated authority as a condition for exemption. The quantities for which the appellants had produced the requisite certificates were therefore entitled to the benefit, while the balance quantity for which no certificate was produced could not qualify. In determining the scope of the exemption, the relevant tariff entry and the exemption notification recognized mustard and rapeseed oil as commercially interchangeable and treated them as one class of fixed vegetable oil. On that footing, the certificate covering rapeseed oil had to be given effect for the quantity so covered, and the denial of benefit only survived for the quantity for which no certificate existed and the claim had not been pressed.

Conclusion: Mustard oil and rapeseed oil were held to be the same commodity for the exemption notification, and the appellants were entitled to exemption for the certified quantity. The demand survived only for the quantity not covered by any certificate.

Ratio Decidendi: Where an exemption notification is framed with reference to a commodity recognized in commercial parlance, identically treated oils cannot be distinguished so as to deny the exemption for the certified quantity if the substantive condition is fulfilled.

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