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    <title>2009 (6) TMI 825 - CESTAT, MUMBAI</title>
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    <description>Exemption and credit notifications must be construed on their plain language, and no extra condition can be added by implication. Where Notification No. 58/97-C.E. required inputs to be received directly from the manufacturer of the inputs, that condition was satisfied by direct supply under invoice even though delivery was made at a job worker&#039;s premises rather than the assessee&#039;s own factory. The decisive test was the directness of the supply transaction, not the physical situs of delivery. On that construction, the assessee remained entitled to the credit benefit and denial of Cenvat credit was unsustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=126681</link>
      <description>Exemption and credit notifications must be construed on their plain language, and no extra condition can be added by implication. Where Notification No. 58/97-C.E. required inputs to be received directly from the manufacturer of the inputs, that condition was satisfied by direct supply under invoice even though delivery was made at a job worker&#039;s premises rather than the assessee&#039;s own factory. The decisive test was the directness of the supply transaction, not the physical situs of delivery. On that construction, the assessee remained entitled to the credit benefit and denial of Cenvat credit was unsustainable.</description>
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