Amending exemption notifications cannot create a standalone exemption where the original notification does not apply to the goods.

An amending exemption notification does not create an independent right to exemption where it merely modifies an original notification that is itself inapplicable to the goods. Tracing cloth could not claim benefit under the later notifications because those instruments had no separate operative force beyond the original exemption scheme. Once the original exemption was unavailable, the amended notifications could not be relied on as standalone sources of relief, so the exemption claim failed and the Revenue's challenge succeeded.

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Issues: Whether the respondents could claim exemption for tracing cloth under the amending notifications when the original exemption notifications were held inapplicable.

Analysis: The dispute concerned exemption notifications governing tracing cloth. The original notifications were held not applicable to the goods. The later notifications were only amendments to those original notifications and had no independent operation. Once the original exemption was unavailable, the amended notifications could not be treated as separate sources of benefit.

Conclusion: The claim to exemption under the amending notifications was not sustainable and the issue was decided against the assessee.

Final Conclusion: The Revenue's challenge succeeded because the amending notifications were held to be inseparable from the original exemption notifications and incapable of supporting an independent claim for exemption.

Ratio Decidendi: An amending exemption notification does not create an independent entitlement where it merely amends an original notification that is itself inapplicable to the goods.

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