https://www.taxtmi.com/caselaws?id=753222 Issue concerns levy of interest and penalty on allegedly delayed payment of central excise duty where goods were exempted under specified notifications. The analysis holds that exemption removes any liability to pay duty, so interest and penalty cannot be imposed for non-payment of exempted duty. Rules cannot create substantive liability for interest or penalty absent a corresponding provision in the Act, and refund mechanisms under the notifications operate as exemptions rather than creating liability. Taxing statutes are to be construed strictly; any ambiguity benefits the taxpayer. Consequently, reliance on procedural rules to levy interest and penalty on exempted duty is impermissible. en-us Fri, 24 May 2024 00:00:00 +0530 Tue, 27 Jan 2026 14:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753222 Issue concerns levy of interest and penalty on allegedly delayed payment of central excise duty where goods were exempted under specified notifications. The analysis holds that exemption removes any liability to pay duty, so interest and penalty cannot be imposed for non-payment of exempted duty. Rules cannot create substantive liability for interest or penalty absent a corresponding provision in the Act, and refund mechanisms under the notifications operate as exemptions rather than creating liability. Taxing statutes are to be construed strictly; any ambiguity benefits the taxpayer. Consequently, reliance on procedural rules to levy interest and penalty on exempted duty is impermissible. Case-Laws Central Excise Fri, 24 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753222