https://www.taxtmi.com/caselaws?id=53461 A duty demand or denial of exemption cannot be sustained on grounds not set out in the show cause notice, and an appellate authority cannot uphold the case on a new basis without fresh notice and opportunity to . The exemption under Notification No. 121/94, as amended, was confined to clearances for use in the factory of the same manufacturer under Chapter X procedure; clearances to another manufacturer's factory did not satisfy that condition. CT-2 certificates alone did not establish entitlement to the substantive exemption. The demand failed only to the extent it rested on new grounds, but the exemption claim failed on the notification's wording. en-us Fri, 20 Aug 2004 00:00:00 +0530 Wed, 13 Oct 2010 14:25:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=53461 A duty demand or denial of exemption cannot be sustained on grounds not set out in the show cause notice, and an appellate authority cannot uphold the case on a new basis without fresh notice and opportunity to . The exemption under Notification No. 121/94, as amended, was confined to clearances for use in the factory of the same manufacturer under Chapter X procedure; clearances to another manufacturer's factory did not satisfy that condition. CT-2 certificates alone did not establish entitlement to the substantive exemption. The demand failed only to the extent it rested on new grounds, but the exemption claim failed on the notification's wording. Case-Laws Central Excise Fri, 20 Aug 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=53461