https://www.taxtmi.com/caselaws?id=42689 An exemption notification must be read as a whole and strictly construed at the stage of determining coverage. The scheme distinguished between factories commencing production after the relevant date and existing factories with enlarged capacity. For an existing factory, the exemption applied only to production attributable to the enlarged capacity, not to goods produced within the pre-existing capacity. Liberal construction could be used only after the assessee had first brought the claim clearly within the notification, and the interpretation adopted avoided discriminatory or incongruous results. en-us Tue, 24 Apr 1990 00:00:00 +0530 Mon, 27 Oct 2025 21:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=42689 An exemption notification must be read as a whole and strictly construed at the stage of determining coverage. The scheme distinguished between factories commencing production after the relevant date and existing factories with enlarged capacity. For an existing factory, the exemption applied only to production attributable to the enlarged capacity, not to goods produced within the pre-existing capacity. Liberal construction could be used only after the assessee had first brought the claim clearly within the notification, and the interpretation adopted avoided discriminatory or incongruous results. Case-Laws Central Excise Tue, 24 Apr 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=42689