Strict construction of exemption notifications bars relief for component goods not constituting the specified exempt product.

Exemption under Notification No. 205/88 was confined to solar flat plate collectors as a complete specified product, and could not be extended to toughened glass sheets merely because they may form part of that collector. The record and departmental scientific opinion showed that the appellant manufactured only toughened glass sheets, not the exempted final product or all its constituent parts. Applying strict construction to exemption notifications, the benefit was correctly denied because the claimed goods did not satisfy the notification's product description.

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Issues: Whether the appellant was entitled to exemption under Notification No. 205/88 for goods cleared as solar flat plate collector, when the appellant was found to be manufacturing only toughened glass sheets.

Analysis: The exemption notification granted relief only to solar flat plate collectors. The record did not establish that the appellant manufactured or supplied all parts of the collector, including the toughened glass sheets as part of the complete collector. The evidence, including the departmental scientific opinion, showed that the appellant's product was only toughened glass sheets and not the exempted final product. As an exemption notification operates as an exception, it must be construed strictly.

Conclusion: The appellant was not entitled to the exemption, and the denial of benefit under Notification No. 205/88 was correct.

Ratio Decidendi: An exemption confined to a complete specified product cannot be extended to a component or input merely because it may form part of that product, and such notifications must be strictly construed.

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