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    <title>2012 (6) TMI 527 - CESTAT, AHMEDABAD</title>
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    <description>Notification No. 39/2001-C.E. was confined to units that had completed the required investment and commenced commercial production by 31-12-2005, and its benefit could not be extended to goods manufactured with plant and machinery installed after that cut-off date in the same factory. Exemption notifications must be construed strictly according to their terms, so a broader area-based purpose could not enlarge the notification beyond its wording. Departmental clarifications and circulars were consistent with this interpretation and treated subsequent investment or fresh machinery installed after the cut-off date as outside the exemption. The refund claim was therefore not admissible.</description>
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      <title>2012 (6) TMI 527 - CESTAT, AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=214215</link>
      <description>Notification No. 39/2001-C.E. was confined to units that had completed the required investment and commenced commercial production by 31-12-2005, and its benefit could not be extended to goods manufactured with plant and machinery installed after that cut-off date in the same factory. Exemption notifications must be construed strictly according to their terms, so a broader area-based purpose could not enlarge the notification beyond its wording. Departmental clarifications and circulars were consistent with this interpretation and treated subsequent investment or fresh machinery installed after the cut-off date as outside the exemption. The refund claim was therefore not admissible.</description>
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