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Issues: (i) Whether the benefit of the small scale industry exemption could be denied because each product manufactured was not specifically endorsed in the registration certificate; (ii) whether a change of factory address affected the validity of the registration certificate.
Issue (i): Whether the benefit of the small scale industry exemption could be denied because each product manufactured was not specifically endorsed in the registration certificate.
Analysis: The exemption question was governed by Notification No. 1/93-C.E. The Tribunal followed its earlier view that the registration certificate need not list every product manufactured by the unit in order to claim the SSI exemption. The absence of specific endorsement for each item was therefore not decisive.
Conclusion: The denial of exemption on the ground that all products were not separately specified in the registration certificate was not justified.
Issue (ii): Whether a change of factory address affected the validity of the registration certificate.
Analysis: The Tribunal held that the validity of the SSI registration certificate was not defeated merely because the factory had shifted to another premises. The reasoning was consistent with earlier Tribunal decisions, including the position that a change of address by itself does not extinguish the certificate for exemption purposes.
Conclusion: The change of address did not invalidate the registration certificate.
Final Conclusion: The exemption could not be denied on either ground, and the Revenue's challenge failed.
Ratio Decidendi: For SSI exemption, a registration certificate need not specifically enumerate every product manufactured, and a mere change of factory address does not by itself invalidate the registration certificate.