Plain language governs exemption eligibility for paper manufactured from qualifying pulp, without implying an exclusion for waste paper.

Paper and paper board manufactured from pulp containing at least 50% by weight of pulp made from materials other than bamboo, hardwoods, softwoods, reeds and rags remained eligible for exemption under Notification No. 25/84-C.E. The decisive issue was the character of the pulp used in manufacture, not the original source of any waste paper from which it was derived. Because the notification did not exclude waste paper, such an exclusion could not be implied. A Board clarification on a similarly worded notification was treated as supporting the same construction. The exemption was therefore available on the notification's plain language.

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Issues: Whether paper and paper board manufactured from pulp using waste paper containing some wood remained eligible for exemption under Notification No. 25/84-C.E. dated 1-3-1984.

Analysis: The notification granted exemption to paper and paper board manufactured out of pulp containing not less than 50% by weight of pulp made from materials other than bamboo, hardwoods, softwoods, reeds and rags. The decisive consideration was whether the pulp used by the assessee satisfied that description. The notification did not exclude waste paper, and the Department could not read such an exclusion into the text by implication. The source from which the waste paper had originally been made was not relevant once the pulp used for manufacture fulfilled the notified condition. The clarification issued by the Central Board of Excise and Customs under the cited letter was also treated as supporting the assessee's eligibility under similarly worded notifications.

Conclusion: The paper manufactured from the disputed pulp was eligible for the exemption and the Revenue's objection failed.

Final Conclusion: The exemption notification was applied according to its express language, and the Revenue's appeal was rejected.

Ratio Decidendi: An exemption notification must be construed on its plain terms, and a condition not expressly stated cannot be added by implication to deny the benefit.

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