2012 (4) TMI 65 - SUPREME COURT

Exemption under Notification No.8/97-CE, dated 1.3.1997 - finished goods manufactured by the 100% EOU out of the raw material supplied by another 100% EOU, and subsequently, cleared in the Domestic Tariff Area (DTA) in accordance with the EXIM Policy 1997-2002 – Revenue contended availiability of alternative benefit of Notification No.2/95-CE, dated 4.1.1995 – Held that:- The notification requires to be interpreted in the light of the words employed by it and not on any other basis. There cannot be any addition or subtraction from the notification for the reason the exemption notification requires to be strictly construed by the Courts. The wordings of the exemption notification have to be given its natural meaning, when the wordings are simple, clear and unambiguous. Therefore, Tribunal has rightly allowed the benefit of exemption under Notification no. 8/97-CE – Decided against the Revenue.