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    <title>2005 (2) TMI 116 - Supreme Court</title>
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    <description>Exemption under Notification No. 123/81-C.E. was available only where the goods were actually used in the manufacture of articles meant for export, not merely in connection with manufacture. The notification had to be read as a whole: although the preamble used wider language, the operative condition controlled eligibility and required a direct manufacturing nexus. Exemption notifications must be strictly construed, and the assessee had to prove with evidence that the particular goods participated in the manufacturing process. On that footing, items such as tables, chairs and air-conditioners were not shown to have the required nexus with the manufacture of cotton or filament yarn, so the exemption was unavailable.</description>
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    <pubDate>Thu, 17 Feb 2005 00:00:00 +0530</pubDate>
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      <title>2005 (2) TMI 116 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=47210</link>
      <description>Exemption under Notification No. 123/81-C.E. was available only where the goods were actually used in the manufacture of articles meant for export, not merely in connection with manufacture. The notification had to be read as a whole: although the preamble used wider language, the operative condition controlled eligibility and required a direct manufacturing nexus. Exemption notifications must be strictly construed, and the assessee had to prove with evidence that the particular goods participated in the manufacturing process. On that footing, items such as tables, chairs and air-conditioners were not shown to have the required nexus with the manufacture of cotton or filament yarn, so the exemption was unavailable.</description>
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