Plain wording of exemption notification covered emulsifiers and wetting out agents without requiring separate surface-active status.

A separate exemption entry for emulsifiers, wetting out agents, softeners and similar preparations intended for use in an industrial process was read on its plain wording, without adding a further requirement that the goods themselves be surface-active preparations. CEGAT noted that the Revenue did not dispute the products' character as emulsifiers and wetting out agents, and held that the notification clearly covered them under the relevant serial number. The exemption under Notification No. 101/66-C.E. was therefore available to the products, and the Revenue's challenge failed.

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Issues: Whether emulsifiers, wetting out agents, softeners and other like preparations were entitled to exemption under Notification No. 101/66-C.E. dated 17-6-1966, and whether such goods had to be surface-active preparations to qualify for the benefit.

Analysis: The notification contained a separate entry for emulsifiers, wetting out agents, softeners and other like preparations intended for use in any industrial process. On a plain reading, that entry did not impose a further condition that such preparations must themselves be surface-active preparations. The Tribunal noted that the Revenue did not dispute that the products were emulsifiers and wetting out agents, and held that the wording of the notification was clear and covered the goods under Sl. No. 2.

Conclusion: The exemption under Notification No. 101/66-C.E. was available to the products in question, and the Revenue's appeal was rejected.

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