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Issues: Whether higher notional credit under the exemption notification was admissible when the inputs were cleared by the small scale manufacturer before the notification ceased, but were received in the user factory only after its cessation.
Analysis: The benefit under the notification was linked to the receipt of inputs in the factory, not merely to their clearance by the supplier. The relevant paragraph expressly extended the credit benefit only where the inputs were received on or after the specified date and before the notification ceased to operate. Since the inputs were received after the expiry of Notification No. 175/86 and the successor notification did not contain an provision, the condition for higher notional credit was not satisfied.
Conclusion: The claim for higher notional credit was rightly rejected and the assessee failed on this issue.
Final Conclusion: The appeal failed in full and the denial of higher notional credit was upheld.
Ratio Decidendi: A concession under an exemption notification is available only when the statutory condition regarding receipt of inputs in the factory is met during the currency of the notification.