Strict construction of exemption notifications excludes copper bars where the notification covered rods only.

Notification No. 174/84 was confined to rods, including wire rods, and did not extend to copper bars merely because Tariff Item 26A(3)(i) also covered bars. The distinction between rods and bars controlled the scope of the exemption, and the fact that the assessee manufactured only bars placed the product outside the notification's express language. Exemption notifications must be strictly construed, and their benefit cannot be enlarged by implication from the tariff entry. On that reasoning, the notification was held inapplicable to copper bars.

---

---

Issues: Whether Notification No. 174/84 dated 1-8-1984 granted exemption or concessional duty to copper bars manufactured by the assessee, having regard to Tariff Item 26A(3)(i) of the erstwhile Central Excise Tariff and the distinction between "rods" and "bars".

Analysis: The exemption notification expressly referred to rods, including wire rods, and did not mention bars. Although Tariff Item 26A(3)(i) covered copper bars as well as rods, the mere inclusion of both under the tariff entry did not enlarge the scope of the notification. The finding that the assessee manufactured only bars, and not rods, meant that the product was not covered by the words of the notification. Exemption notifications are to be strictly construed and benefit cannot be extended by implication.

Conclusion: The benefit of Notification No. 174/84 was not available to copper bars, and the Revenue's appeal succeeded.

---