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    <title>1991 (11) TMI 136 - CEGAT, NEW DELHI</title>
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    <description>Cement was not eligible for the concessional rate under Notification No. 124/87-C.E. because the clinker used was produced in a separate factory that commenced production only in 1988, outside the period specified in the notification. The notification was construed on its plain language: the concessional rate applied only where cement was manufactured in a qualifying factory and the clinker was produced within the same factory or another factory of the same manufacturer that had also commenced production during the stated period. A harmonious construction was rejected because the wording was clear and unambiguous. The higher duty under Notification No. 35/88-C.E. therefore applied.</description>
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    <pubDate>Thu, 07 Nov 1991 00:00:00 +0530</pubDate>
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      <title>1991 (11) TMI 136 - CEGAT, NEW DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=81593</link>
      <description>Cement was not eligible for the concessional rate under Notification No. 124/87-C.E. because the clinker used was produced in a separate factory that commenced production only in 1988, outside the period specified in the notification. The notification was construed on its plain language: the concessional rate applied only where cement was manufactured in a qualifying factory and the clinker was produced within the same factory or another factory of the same manufacturer that had also commenced production during the stated period. A harmonious construction was rejected because the wording was clear and unambiguous. The higher duty under Notification No. 35/88-C.E. therefore applied.</description>
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