2005 (2) TMI 117
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....stoms Excise and Gold (Control) Appellate Tribunal dated 11th June, 1999. 2. The question for consideration is whether the Respondents (herein) are entitled to the benefit of Notification No. 30/97-C.E., dated 1st August, 1997. The relevant portion of the said Notification reads as follows :- "G.S.R. 445 (E) - In exercise of the powers conferred by sub-section (1) of Section 3A of the Centra....
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.................… (d) ..............… (e) an integrated steel plant which manufactures or produces ingots or billets and rolled products, starting from the stage of iron ore, within the same premises." Facts not in dispute are that the Respondents have a manufacturing unit which has capacity to manufacture or produce ingots or billets or rolled products, starting from the stage of iron o....
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....ld that the Notification does not require that 100% of the Ingots or billets or other rolled products must be manufactured from the stage of iron ore in the factory itself. It is held that merely because the majority of sponge iron is purchased from outside, the benefit of the Notification is not lost. 4. We are thus required to interpret clause (e) of Notification which has been set out herein....
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....ing. No words, not used in the Notification, can be added. To accept submission of Appellants one would have to read into the Notification words to the effect that 100% of the manufacture or production of ingots or billets or rolled products must be from products manufactured or produced within the same premises. No such words appear in the Notification. If the intention was to restrict benefit to....
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