Strict construction of exemption notification denied for rollable or re-rollable scrap not matching the prescribed input description.

Exemption under Notification No. 202/88-C.E. was confined to inputs matching the specific descriptions in the notification's table, and rollable or re-rollable scrap/material did not fall within those eligible inputs. The assessee had the burden to prove strict compliance with the exemption entry, and the invoice descriptions did not establish such entitlement. The claimed benefit therefore failed, and the exemption was not available.

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Issues: Whether the benefit of Notification No. 202/88-C.E. dated 20-5-1988 was available to the respondents for inputs described as rollable or re-rollable scrap/material.

Analysis: The notification granted exemption only where the inputs answered the specific descriptions set out in its table. The recorded material showed that rollable or re-rollable material was not described as one of the eligible inputs in the notification. The burden lay on the assessee to establish that the inputs used fell strictly within the four corners of the exemption entry, and that burden was not discharged. The description in the invoices also did not support entitlement to the notification benefit.

Conclusion: The benefit of Notification No. 202/88-C.E. was not available to the respondents, and the claim to exemption failed.

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