Strict construction of exemption notifications excludes drilled copper castings from treatment as unworked cast articles.

The exemption for cast articles of copper under Notification No. 178/88-C.E. applied only where the casting had not been further worked. Drilling holes in cast solid blocks after removal from the mould changed the casting into spindle nuts and constituted further working, not a mere continuation of casting. Because exemption notifications are construed strictly, the drilled articles did not fall within the notification. The spindle nuts were therefore not eligible for exemption, and the Revenue's view was upheld.

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Issues: Whether spindle nuts cleared after drilling of holes in cast solid blocks were eligible for exemption under Notification No. 178/88-C.E. dated 13-5-1988 as cast articles of copper not further worked.

Analysis: The exemption was confined to cast articles of copper that had not been further worked. After the cast solid blocks were taken out of the mould, they were subjected to drilling, and that process converted the casting into a spindle nut. The drilling was not a mere continuation of casting but amounted to further working. Exemption notifications are to be construed strictly, and the process could not be treated as part of casting for the purpose of the notification.

Conclusion: The spindle nuts were not entitled to the exemption. The Revenue's view was correct.

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