Exemption notifications must be applied on their own terms; captive consumption alone cannot defeat the benefit.

Notification-specific exemption under Notification No. 101/66-C.E. was available for Turkey Red Oil and Det Oil because the notification did not exclude Turkey Red Oil, and the record did not show manufacture or packing of Det Oil with the aid of power or steam. A report relied on by the Revenue was found irrelevant because it addressed a different notification. Exemption under Notifications No. 71/78-C.E. and No. 80/80-C.E. could not be denied merely because the clearances were for captive consumption, as captive use was not a disqualifying factor under those notifications.

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Issues: (i) Whether exemption under Notification No. 101/66-C.E. was admissible to Turkey Red Oil and Det Oil; (ii) whether exemption under Notification No. 71/78-C.E. and Notification No. 80/80-C.E. could be denied on the ground that the clearances were for captive consumption.

Issue (i): Whether exemption under Notification No. 101/66-C.E. was admissible to Turkey Red Oil and Det Oil.

Analysis: The notification was found to contain no condition excluding Turkey Red Oil. As to Det Oil, it was treated as an organic surface active agent preparation containing soap, and the relevant requirement was that no process in or in relation to manufacture or packing of such preparation should ordinarily be carried on with the aid of power or with steam or heating. The record did not show any such process with the aid of power or steam, and the report relied upon by the Revenue was held to be in the context of a different notification and not decisive for Notification No. 101/66-C.E.

Conclusion: Exemption under Notification No. 101/66-C.E. was held admissible to both Turkey Red Oil and Det Oil.

Issue (ii): Whether exemption under Notification No. 71/78-C.E. and Notification No. 80/80-C.E. could be denied on the ground that the clearances were for captive consumption.

Analysis: The lower appellate authority held that captive consumption did not by itself justify denial of the benefit under those notifications, and no infirmity was found in that view.

Conclusion: The denial of exemption on the ground of captive consumption was rejected.

Final Conclusion: The assessee's entitlement to the exemption benefits was upheld and the Revenue's challenge failed.

Ratio Decidendi: A notification-specific exemption cannot be denied by importing conditions or technical findings arising under a different notification, and captive consumption cannot be treated as a disqualifying factor unless the notification so provides.

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