Strict construction of exemption notification limits clearance-based benefit to one factory; multiple-factory clubbing is not permitted.

Notification No. 6/88-C.E. was construed strictly on its plain language, with the exemption limited to clearances from the relevant factory and not aggregated across multiple factories of the same manufacturer. The expression "from any factory" was treated as factory-specific, and the phrase "aggregate quantity" was read as the total quantity cleared during the year from that factory alone. Because the notification did not use broader language such as "from any one or more factories," clubbing of clearances from two factories was not permissible. The differential duty demand was therefore sustained, and the exemption was held unavailable on a manufacturer-wise basis.

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Issues: Whether the benefit of Notification No. 6/88-C.E. had to be computed factory-wise, and whether clearances from more than one factory of the same manufacturer could be clubbed for applying the 5% limit on fents and rags of man-made fabrics.

Analysis: The exemption notification used the expression "from any factory" and did not say "from any one or more factories". The notification was therefore required to be construed strictly on its plain language, without importing words not used by the legislature. The phrase "aggregate quantity" was read as the total quantity cleared during the year from the relevant factory, and where the Government intended a manufacturer-wise or multiple-factory basis, the language used in the notification expressly so indicated. The clearances for the purpose of the exemption were thus to be determined with reference to the factory from which the goods were cleared.

Conclusion: The exemption was available only on a factory-wise basis. Clubbing of clearances from two factories was not permissible, and the demand of differential duty was upheld against the assessee.

Ratio Decidendi: An exemption notification must be interpreted strictly according to its express words, and where it limits the benefit to clearances "from any factory", the court cannot expand it to cover multiple factories or a manufacturer-wise aggregation in the absence of such language.

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