Exemption for factory-made excisable goods cannot extend to imported spares unless the notification expressly covers imports.

Imported spares cleared on payment of duty and countervailing duty were held outside Notification No. 271/86-C.E. because the exemption was confined to excisable goods manufactured in a workshop within a factory and intended for use in that factory or another factory of the same manufacturer. The notification applied only to goods manufactured in India and covered by Central Excise law, so imported consignments did not satisfy its conditions. As the goods were brought into India, the benefit could not be extended to them for relief from C.V.D., and the denial of exemption was upheld.

---

---

Issues: Whether imported spares cleared on payment of duty and C.V.D. were entitled to exemption under Notification No. 271/86-C.E. dated 24-4-1986.

Analysis: The exemption was confined to excisable goods manufactured in a workshop within a factory and intended for use in that factory or another factory of the same manufacturer. Imported goods did not satisfy the condition that the goods must be manufactured in India and be goods covered by Central Excise law. As the consignments were imported into India, the notification could not be extended to them for relief from C.V.D.

Conclusion: The appellants were not entitled to the exemption under the notification and the denial of benefit was upheld.

Ratio Decidendi: An exemption notification confined to excisable goods manufactured within India cannot be applied to imported goods unless its conditions expressly extend to such imports.

---