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    <title>1994 (12) TMI 74 - Supreme Court</title>
    <link>https://www.taxtmi.com/caselaws?id=43897</link>
    <description>The exemption under Notification No. 61/71, as amended, was confined to the vegetable product shown to be made from indigenous rice bran oil, not to the entire quantity of admixture cleared from the factory. The controlling language linked the concession to the extent the final product satisfied the notification&#039;s condition, and the tribunal&#039;s construction was found consistent with that wording. Applying the strict rule of interpretation for fiscal exemptions, any ambiguity was resolved against the assessee and in favour of the revenue. The assessee therefore could not claim exemption on the whole admixture, and the demand revision was upheld.</description>
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    <pubDate>Tue, 13 Dec 1994 00:00:00 +0530</pubDate>
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      <title>1994 (12) TMI 74 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=43897</link>
      <description>The exemption under Notification No. 61/71, as amended, was confined to the vegetable product shown to be made from indigenous rice bran oil, not to the entire quantity of admixture cleared from the factory. The controlling language linked the concession to the extent the final product satisfied the notification&#039;s condition, and the tribunal&#039;s construction was found consistent with that wording. Applying the strict rule of interpretation for fiscal exemptions, any ambiguity was resolved against the assessee and in favour of the revenue. The assessee therefore could not claim exemption on the whole admixture, and the demand revision was upheld.</description>
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      <pubDate>Tue, 13 Dec 1994 00:00:00 +0530</pubDate>
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