Strict construction of exemption notifications barred benefit for input scrap outside the specified eligible categories.

Exemption Notification No. 202/88-C.E. was treated as inapplicable because the input materials were classified as old and unserviceable re-rollable scrap, not as angles, shapes and sections covered by the notification. The Tribunal applied the principle that an exemption notification must be strictly construed, and benefit cannot be extended to inputs outside the categories expressly specified. On that basis, the Revenue's denial of exemption was sustained and the assessee was found not entitled to the benefit.

---

---

Issues: Whether the assessee was entitled to the benefit of Exemption Notification No. 202/88-C.E. dated 20-5-1988 in respect of the input materials used.

Analysis: The input materials were held to be classifiable as old and unserviceable re-rollable scrap and not as angles, shapes and sections. Since such materials were not specified as eligible inputs under the notification, the exemption was held to be unavailable. The appeal was decided by following the earlier Tribunal decision on the same issue.

Conclusion: The assessee was not entitled to the exemption benefit.

Final Conclusion: The appeal failed and the Revenue's view denying exemption was sustained.

Ratio Decidendi: An exemption notification must be strictly construed, and benefit cannot be granted where the input material does not fall within the inputs specifically covered by the notification.

---