Strict construction of exemption notifications prevents extension of compressor parts relief to crankshafts outside covered tariff headings.

Exemption under Notification No. 16/86-C.E. was confined to parts of gas compressors falling within the tariff headings expressly covered by the notification and to compliance with the prescribed procedure. A crankshaft used in compressors was classified under a different tariff heading, so it did not fall within the notification's clear scope. The cited Supreme Court ruling was inapplicable because it concerned differently worded exemption language. In taxing notifications, exemption must be construed strictly according to the express terms used, and cannot be extended by intendment or implication. The crankshaft was therefore outside the exemption.

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Issues: Whether crankshaft used in compressors was entitled to exemption under Notification No. 16/86-C.E. dated 1-3-1986.

Analysis: The exemption notification specifically covered only those parts of gas compressors falling under the tariff headings mentioned in the notification and required compliance with the prescribed procedure. The crankshaft was classifiable under a different tariff heading, and the cited Supreme Court decision on a differently drafted notification did not apply. In a taxing notification, exemption must be confined to the clear language used, with no scope for intendment or expansion by implication.

Conclusion: The crankshaft did not qualify for the exemption and the appeal failed.

Final Conclusion: The denial of exemption was upheld on the basis that the notification was to be applied strictly according to its express tariff coverage.

Ratio Decidendi: An exemption notification in a taxing statute must be construed strictly according to its clear language, and benefits cannot be extended to goods falling outside the tariff headings specifically covered.

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