Exemption notification interpretation: aggregate clearance limit prevailed, and the Revenue could not deny relief on a chapter-wise threshold objection.

Exemption under Notification No. 175/86 was held available where aggregate clearances stayed within the prescribed limit, even though clearances under one chapter exceeded the chapter-wise threshold. The Tribunal treated its earlier interpretation as settled by consistent subsequent decisions and by the Supreme Court's rejection of the Department's challenge in connected proceedings, and held that the contrary view in Ramakrishna Engineering Works did not govern. On that basis, the Revenue's objection based on the chapter-wise limit failed and the exemption was allowed to stand.

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Issues: Whether the assessee was entitled to the benefit of Notification No. 175/86 dated 01-03-1986 where the aggregate clearances remained within the prescribed limit of Rs. 30 lakhs, though clearances under one chapter exceeded Rs. 15 lakhs.

Analysis: The Tribunal followed its earlier decisions holding that the issue stood concluded by precedent. It noted that the view in Ramakrishna Engineering Works had been considered and not accepted in subsequent Tribunal decisions, including cases affirming that the decision in EL.P.EM. Industries remained the governing interpretation. The Tribunal also relied on the fact that the Apex Court had dismissed the departmental challenge to the related Tribunal view, and therefore the controversy was no longer res integra. On that basis, the exemption notification was read as permitting the benefit notwithstanding the chapter-wise clearance contention raised by the Revenue.

Conclusion: The assessee was entitled to the exemption, and the Revenue's objection based on the Rs. 15 lakhs chapter-wise limit was rejected.

Final Conclusion: The Revenue appeal failed and the order allowing the assessee's appeal was left undisturbed.

Ratio Decidendi: Where the Tribunal's interpretation of an exemption notification has been consistently followed and accepted by the Supreme Court in connected proceedings, that interpretation governs and the Revenue cannot deny exemption by relying on a contrary earlier view.

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