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TMI Blog2010 (10) TMI 649X X X X Extracts X X X X X X X X Extracts X X X X ..... -C.E., dated 1-3-2000, as amended by Notification No. 36/2000-C.E., dated 4-5-2000 for the period prior to 28-2-2001 and of the Notification No. 3/2001-C.E., dated 1-3-2001 for the period from 1-3-2001 onwards. The assessees are engaged in the manufacture of various types of intravenous fluids. They had been claiming benefit under Notification No. 6/2000-C.E., dated 1-3-2000 as amended by the Notification No. 36/2000-C.E., dated 4-5-2000 whereby the intravenous fluids were exempted from payment of excise duty. With effect from 1-3-2001, the same was replaced by Notification No. 3/2001-C.E., dated 1-3-2001, whereby the exemption from payment of duty was provided in relation to intravenous fluids, which are used for sugar, electrolyte and fluid replenishment. The appeals by the department are against the orders granting such benefits under the said notifications. 3. Since the Department sought to deny the benefit of the said notifications on the ground that the benefit under those notifications was restricted to those intravenous fluids, which are used for sugar, electrolyte and fluid replenishment, the benefit thereunder being not available for those intravenous fluids which a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Metronidazole I.P. (c) PDZOLE - D (d) Ciprodex (e) Tinipidi Isotonic Infusion, and (f) Mannitol I.P. The most important aspect to be noted is that in the 2001- 2002 Budget, an explanation was inserted in Notification No. 36/2000, clarifying that only such IV fluids which were used for sugar, electrolyte or fluid replenishment, were exempt from duty and not other IV fluids. This provision in the Budget was relied upon by the Department in the show cause notice (s) to deny the benefit of exemption claimed by the respondents under Notification No. 3/2001. Unfortunately, despite detailed analysis of the notification in question by the Commissioner, the Tribunal has not examined this aspect and, therefore, the matter needs to be remitted to the Tribunal to give its finding as to what is the effect of the 2001-2002 Budget which restricts the definition of 'IV Fluids' in terms of the above three qualifications. There is one more aspect which the Tribunal is required to consider. In the labels of the respondent-company, there is a warning stating that IV Fluid manufactured by the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n set aside by the Hon'ble Supreme Court. 6. The Hon'ble Supreme Court has also observed that the Tribunal has to consider the point relating to the label affixed to the containers of their products stating that IV fluids manufactured by the assessees are scheduled H Drugs. Findings are expected on both these issues and therefore both the questions/issues need to be considered by the Tribunal in accordance with law, and hence the matter has been remanded. 7. The Hon'ble Supreme Court has also reminded that the exemption notifications are to be read strictly and that burden lies upon the assessees to prove that the item falls within the four corners of the exemption notification. The Hon'ble Supreme Court also observed that as regards the issue regarding Schedule H drug is concerned, if the Tribunal feels it necessary, may permit the parties to lead further evidence in relation to the said issue. 8. The matter has been remanded essentially to decide the two issues specified by the Hon'ble Supreme Court in the remand order. The issues are, firstly, the effect of 2001-2002 Budget, which describes the product of IV fluids with three qualifications viz. that IV fluids ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Icoccel, Icoamin, Isodex M & P, Glydex. The Commissioner had confirmed the demand to the tune of Rs. 34,16,637/- with interest and had imposed penalty of Rs. 2 Lakh under Rule 173Q read with Rule 25 of the Central Excise Rules. It also related to the show cause notice dated 24-4-2003, which pertained to the period from April, 2002 to 31-12-2002 and the Commissioner confirmed the demand to the tune of Rs. 37,48,361/- along with interest thereon and imposed penalty of Rs. 2 Lakh under Rule 25 of the Central Excise Rules. 12. The Excise Appeal No. E/3110 of 2003 and Appeal No. E/3519 of 2004 have been filed by M/s. Venus Remedies Ltd. Therein the show cause notice was issued on 29th October, 2002 and the period involved was from March, 2001 to April, 2002. The products involved were Renaid, Metronidazole, Mannitol, Metrinidazole, Cipro, Mical, Vefloxin, Metro-Vet, Atropine Sulphate, Calcia, Ofloxin, Glycin Irrigation Solution and Detox. The Commissioner has confinned the demand of Rs. 18,12,240/- along with interest and imposed equal amount of penalty. Besides, he has also confirmed the demand of Modvat credit of Rs. 22,046/- along with interest thereon and has appropriated cred ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m Chloride Irrigation. The Adjudicating Authority therein had confirmed the demand of duty to the tune of Rs. 10,59,490/- along with interest and equal amount of penalty. The Commissioner (Appeals) set aside the order to the extent of Rs. 9,64,998/- and confirmed demand only to the tune of Rs. 94,498/- while holding that there was no suppression of any facts and therefore the penalty was set aside. 16. The Excise Appeal No. E/4739 of 2004 has been filed by the Department against the order passed by the Commissioner of Central Excise (Appeals), Indore on 14-6-2004. The period involved was from May, 2000 to March, 2001 and a show cause notice was issued on 30-6-2001. The products involved therein were Ciprofloxacin, Mannitol, Metronidazole and Berrizole Injections. The Adjudicating Authority therein had confirmed the demand to the tune of Rs. 3,27,190/- with interest and had imposed equal amount of penalty. The Commissioner (Appeals) has set aside the entire order of the adjudicating authority. 17. The Excise Appeal No. 4860 of 2004 has been filed by the Department against the order passed by the Commissioner of Central Excise (Appeals), Indore on 13-6-2004. The period in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eriod from 1-3-2001 onwards in respect of the products in question. It is in relation to the said controversy that we have to find out the effect of 2001-2002 Budget which describes the product namely IV fluids with three qualifications and the effect of the warning disclosed in the labels on the containers of the products in question. 21. During the pendency of the proceedings, after remand, the assessees filed applications for production of additional evidence in terms of Rule 23 of CESTAT Procedure Rule 1982. The Rule 23(1) of CESTAT (Procedure) Rules provides that "the parties to the appeal shall not be entitled to produce any additional evidence either oral or documentary, before the Tribunal, but if the Tribunal is of the opinion that any document should be produced or any witness should be examined or affidavit should be filed to enable it to pass orders or for any sufficient cause, or if adjudicating authority or the appellate or revisional authority has decided the case without giving sufficient opportunity to any party to adduce the evidence on the points specified by them or not specified by them, the Tribunal may, for the reasons to be recorded, allow such documen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le H Drug, the question of allowing the parties to produce additional evidence in relation to any other issue does not arise, unless the Tribunal itself is of the opinion that such evidence is necessary to meet the ends of justice as provided under Rule 23 (4) of the CESTAT (Procedure) Rules. 26. Bare perusal of the applications seeking leave to produce additional evidence filed by the assessees discloses that the same are sought to be produced in answer to the question relating to the effect of addition of various medicaments and drugs to the IV fluids and whether the mixture of anti-biotics and such fluids would justify the denial of exemption under the said notification. This is apparent from para-11 of the applications filed by the assessees. 27. It is settled law, and the assessees are very well knew that the matters relate to the claim of exemption benefit and therefore the burden in that regard squarely lies upon the assessees to establish the claim and therefore it was necessary for the assessees to produce all the materials in support of their claim before the adjudicating authority. This was necessary not only to establish the claim of the assessees but also t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eunder was assured to "intravenous fluids" without any prefix or suffix and without any restriction or qualification. Both notifications merely referred to intravenous fluids classifiable under Chapter 30 of the Central Excise Tariff Act without any reference to and without being qualified by any word or expression either as condition relating to the use of such products, or relating to the composition thereof. 33. Though all throughout the proceedings before the lower authorities, it was sought to be contended that the Notification No. 3/2001 will have retrospective effect, the learned Advocate appearing for the department has fairly conceded that it is difficult to support the said contention. Even otherwise, under the remand order itself, the point stands concluded as the Hon'ble Supreme Court has in the remand order itself clearly held that the earlier notifications were without any qualifications in contradiction to those prescribed under the changes brought about in the new notification. 34. As regards the said Notification No. 3/2001, the same specifically speaks of intravenous fluids which are used for sugar, electrolyte or fluid replenishment classifiable under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndia v. Tata Iron and Steel Co. Ltd., reported in 1977 (1) E.L.T. J61, Gujarat State Fertilizers Co. v. Collector of Central Excise reported in 1997 (91) E.L.T. 3, Compack Pvt. Ltd. v. Commissioner of Central Excise, Vadodara reported in 2005 (189) E.L.T. 3 and Commissioner of Customs, Kolkata v. Rupa & Co. Ltd. reported in (2004) 6 Supreme Court Cases 408 = 2004 (170) E.L.T. 129 (S.C.) According to the ld. Advocates if the primary function of the intravenous fluid continues to be one for the use of sugar, electrolyte or fluid replenishment and the same simultaneously carries with it other drug or medicament as incidental to its main function, the product then would not change its identity or character as the intravenous fluid. Bearing in mind this fundamental concept, the product in question merely because it contains drugs and medicaments cannot be denied the benefit assured under the said notification. 37. It is also sought to be argued on behalf of the assessees that there is a complete fallacy in the Revenue's assumption that the intravenous fluids in question are used merely as a carrier for vehicle for other drugs. Intravenous fluids for sugar, electrolyte or fluid rep ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... extracts from Remington's Science and Practice of Pharmacy, and affidavit of Dr. Ram Irani, in support of their submissions. All these materials, however, are sought to be produced along with the applications seeking leave to adduce additional evidence. 40. As regards the issue relating to the Schedule H drugs, it is sought to be contended on behalf of the assessees that the notification grants exemption in respect of all intravenous fluids used for sugar, electrolyte or fluid replenishment and it makes no reference nor provides any restriction with regard to Schedule H drug. The effect of the warning about Schedule H drug is that the goods have to be sold by retailer only on prescription of a registered medical practitioner and it does not speak of use or pharmacological category of the medicine and this is evident from the certificate dated 28-8-2009 issued by the licensing authority. 41. The ld. Advocate appearing for the department, on the other hand, has submitted that the notification restricts the benefit to those intravenous fluids which are used for specified purposes. It does not include any other purpose. To assume that the notification does not bar simultane ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s fluids. 44. It is further contention on behalf of the department that the budget Explanatory note of 2000-01 clearly clarified that intravenous fluids exempted under Notification No. 36/2000 are those meant to be used for sugar, electrolyte or fluid replenishment. Attention is drawn to the decision of the Supreme Court in the matter of Collector of Central Excise v. Parle Exports (P) Ltd. reported in 1988 (38) E.L.T. 741 (S.C.), while contending that a notification is to be treated as if it is enacted in the Act itself. 45. While contending that the term intravenous fluids has distinct connotation in medical parlance, it is further submitted on behalf of the department that under Chapter 30 of the Tariff Act, no distinction has been made between oral antibiotics and intravenous antibiotic injection. Obviously, it could not be assumed that the intention of the legislature was to make a special dispensation by exempting intravenous antibiotic injections from duty while levying duty on oral antibiotics in the absence of specific and clear notification in that regard. If that was the intention, it would have clearly reflected in the notification itself. Even assuming that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he brand name "Aminomix", the product composed of a mixture of Amino acid, glucose (Carbohydrates) and electrolytes. The Tribunal while observing that, admittedly, the goods were composed of "Intravenous Amino acid" along with glucose and a variety of electrolyte and that they were life saving drugs and that such life saving drugs were covered under Sr. No. 50 (A) of Notification No. 20/99 and under Sr. No. 80(A) of Notification No. 16/2000 and further taking note of scientific literature has observed that, the Amino acid would optimally benefit patients in the presence of carbohydrates, electrolytes etc. Further, it has been held that the functional ingredient being Intravenous amino acid, the benefit of the notification would be available to the product. Reliance has been placed in the decision of the Tribunal in the matter of Commissioner of Customs, Chennai v. Tablets (India) Ltd. reported in 2005 (191) E.L.T. 280, further order by the Apex Court in the same matter reported in 2006 (198) E.L.T. A36 and Tata Iron and Steel Co. Ltd. (supra), while observing that, the Supreme Court took the view that the benefit was not available "exclusively" or "only" to duty paid pig iron inasm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... if it was produced out of scrap obtained from duty paid pig iron, the duty payable was Rs. 30 PMT and if produced out of old iron or steel or scrap obtained from duty paid steel ingots or products, the duty payable was Nil. The said rates were further amended under Notification No. 22/64 dated 1st March 1964 whereby the words and figures "Rs. 29.35 per metric ton" were substituted which by "Rs. 20 per ton" in relation to the rates specified in Notification No. 30/60 dated 1st March 1960. 52. The facts of the TISCO's case as revealed from the judgment of the Apex Court are that the duty was realised from the assessee on steel ingots in the making of which duty paid pig iron of rejected ingot moulds and bottom stools were used along with non-duty paid materials. The assessee had claimed exemption in respect of duty paid pig iron on rejected moulds and bottom stools used in the manufacture of steel ingots. The claim was rejected by the revenue authorities. When the matter was challenged before the High Court the orders of the Revenue authorities were quashed, while observing that the notification did not use the words like 'entirely', 'exclusively' or 'only' but only exempted st ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . The description of the produce related to the utilisation of an input while manufacturing the final product which would be entitled to take the benefit of exemption. It is common knowledge that the final product of the nature described in the notification could not have been manufactured with the use of sole input described in the notification. In those circumstances, the High Court and Apex Court came to the conclusion that in the absence of the words like 'entirely', 'exclusively' or 'only', the benefit of notification cannot be restricted to a product with the exclusion of use of other inputs along with the inputs identified under the notification. It is so because the final product could not have been manufactured without utilisation of other inputs alongwith the one identified under the notification. Certainly the absence of words like 'exclusively', 'only' or 'entirely' restricting the benefit would have resulted in defeating the very purpose of the notification. The reasonings narrated by the Apex Court in para-22 quoted above clearly disclose the justification for the view taken in the facts and circumstances of the case wherein the notification does not permit any such r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tatute. While it has been argued on behalf of the department that exemption notification ought to be interpreted strictly and the burden is upon the assessees to establish that their products are entitled to avail the exemption, on the other hand, on behalf of the assessee, the Tribunal has been repeatedly reminded that under the guise of interpretation it is neither permissible to add something to the notification nor to subtract therefrom. 56. Undoubtedly, law on the point that the exemption notification has to be understood on the basis of the grammatical meaning of the words used in such notification unless context otherwise requires is well settled. It is well settled law that in a taxing statute there is no room for any intendment but regard must be had to the clear meaning of the words". The entire matter is to be governed wholly by the language used in a notification. If the tax-payer is within the plain terms of the exemption, it cannot be denied its benefit by calling in aid any supposed intention of the exempting authority. If such intention can be gathered from the construction of the words of the notification or by necessary implication therefrom, the matter coul ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reiterated in the said decision at page 369 of the report that in a taxing Act provisions establishing an exception to the general rule of taxation are to be construed strictly against those who invoke its benefit. While interpreting an exemption clause, liberal interpretation should be imparted to the language thereof, provided no violence is done to the language employed. It must, however, be borne in mind that absurd results of construction should be avoided". 58. In Hemraj Gordhandas (supra), the Apex Court had held that in a taxing statute, there is no room for any intendment but regards must be had to the clear meaning of the words. The entire matter should be governed wholly by the language of the notification. 59. The Apex Court in CCE, Hyderabad v. Sunder Steels Ltd. reported in 2005 (181) E.L.T. 154 had clearly ruled that the notification has to be interpreted on its wordings and no words, not used in the notification can be added. 60. Bombay Oil Industries Pvt. Ltd. v. Union of India reported in 1995 (77) E.L.T. 32 (S.C.) it was held that it is trite to say that in order to earn the exemption, the person claiming the exemption must satisfy that his impo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e department by issuing a circular to subsequent to the notification could not add new condition to the notification thereby restricting the scope of exemption notification or whittling it down. 66. In Gujarat State Fertilizers Co. (supra), it was clearly held that by catena of decisions, it is now well settled that for deciding whether an exemption notification gets attracted on the facts of a given case, the expressed language of the exemption notification has to be given its due effect, and due emphasis are to be given to the clear language of the condition mentioned in the exemption notification. It was further held that it must be kept in view that the object and the purpose of the exemption has to be culled out from the expressed language of the notification. If the express language of the notification does not indicate a contrary intention conveyed by the wide words employed by the notification, full effect has to be given to the wide terminology employed by the notification otherwise the result would be that in trying to search for the supposed intention underlying the notification, the intention flowing from the expressed language of the notification would get stulti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion to the use of the product to be eligible to claim the exemption benefit, whereas the assessees contend that the same cannot be enforced retrospectively. Reliance is placed in the decision in the matter of Collector of Central Excise, Shillong v. Wood Craft Products Ltd. reported in 1995 (77) E.L.T. 23 on behalf of the department whereas on behalf of the assessees, reliance is placed in the decision in the matter of the Cannanore SPG & WVG. Mills Ltd. v. CCE reported in 1978 (2) E.L.T. J375 (S.C.), Bombay Oil Industries Pvt. Ltd. v. Union of India reported in 1995 (77) E.L.T. 32 and P. Mahendran & Ors v. State of Karnataka & Ors. reported in 1990 (1) SCC 411. 71. At the outset, it is to be noted that the Explanatory Note never formed part of any notification including the Notification No. 36/2000 as is apparent from the said notification itself. It was in relation to the budget for the year 2001-2002 while referring to the exemption in the changed form incorporated under the new Notification No. 3/2001, dated 1-3-2001, which came into force from the said date. The said changes were clarified under the explanatory note to the budget. What is stated in the Note is that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n No. 3/2001, which came into force w.e.f. 1-3-2001 and not prior thereto. This covers first part of the said issue. 75. The second part of the issue relates to three qualifications. It is to be noted that we are dealing with the matter relating to the claim for exemption to the product manufactured by the assessee. This is not a matter relating to the dispute pertaining to classification. The notification ex facie describes the product, which is eligible to claim the exemption benefit thereunder. A person claiming the benefit of exemption under a notification in relation to a product which does not correspond to the description given in the notification, by applying the theory of implied inclusion of such product under the notification, has to establish the same by cogent evidence. As already observed above, the burden in that regard rests exclusively upon such claimant. This has also been reiterated by the Apex Court in the remand order itself. 76. The notification in question specifically refers to the expression "intravenous fluids which are used for sugar, electrolyte or fluid replenishment" with effect from 1st March 2001 and prior to that the same used the expres ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cept of aseptic conditions and reduces irritation potential of the drug. The very fact that the product having such mixture of drugs are meant for totally different function, purpose and effect, apparently discloses that pursuant to such mixture of drugs, the product does not remain merely to be intravenous fluids used for sugar, electrolyte or fluid replenishment. The product acquires a totally different character. It has different purpose and use. 80. The contention that notification grants the exemption in respect of all the intravenous fluids for sugar, electrolyte or fluid replenishment is totally devoid of substance. As already pointed out above, the expression referring to the exempted product is not prefixed by the word "all", rather it specifically restricts to those intravenous fluids which are used for specified purposes and no other intravenous fluids. 81. Perusal of the report on intravenous fluids by the Institute of Chemical Technology, Mumbai, affidavit of doctor, Remington's Science and Practice of Pharmacy does not render any assistance to the appellant's case. The contention that additions of drugs do not change the basic character of the product i.e. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on application of common parlance theory. The contention that the character of the IV Fluids would not change pursuant to the mixture of anti-biotics with such product cannot be accepted. In order to be eligible to claim the benefit under the said notification, the product has to satisfy the description of the product given under the notification. Mixture of antibiotics with IV Fluids cannot be construed as included in the product named and identified for exemption benefit under the said notification. 84. In Dabur (India) Ltd. v. Commissioner of Central Excise, Jamshedpur reported in 2005 (182) E.L.T. 290 (S.C.) a Bench of three Hon'ble Judges of the Supreme Court held that in classifying a product the scientific and technical meaning is not to be resorted to. The product must be classifiable according to the popular meaning attached to it by those using the product. Referring to the facts of the case before the Apex Court, it was held that the assessee had shown that all the ingredients in the product were those which were mentioned in the Ayurvedic Text Books. That by itself would not have been sufficient, however, the assessee had shown that they had a Drug Controller ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt, power-generating sets, machine tools, catalysts for initial charge, and equipments and instruments for testing, research and development, quality and pollution control; (b) use in manufacturing, mining, agriculture, aquaculture, animal husbandry, floriculture, horticulture, pisciculture, poultry, viticulture and sericulture; and xx xx xx xx xx" Taking into consideration the meaning of the term 'capital goods' under the said notification, which clearly included the goods specified as well as other related goods, it was held thus :- "8. Further, in our view, this notification is very clear. The 100% exemption is given to capital goods required for manufacture of, amongst others, "textile garments". The term 'capital goods' has been defined in the notification. The term "capital goods" means which are used in the manufacture of that product and also goods which would be required for manufacture or production of other goods including packaging machinery and equipments. The term also includes instruments for testing, research and development. The term includes machines for pollution ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as if it was a statutory definition. It will require qualification in new circumstances," Megarry, J. in (1971) 1 WLR 1062 observed : "One must not, of course, construe even a reserved judgment of Russell L.J. as if it were an Act of Parliament." And, in Herrington v. British Railways Board [1972 (2) WLR 537] Lord Morris said : "There is always peril in treating the words of a speech or judgment as though they are words in a legislative enactment, and it is to be remembered that judicial utterances made in the setting of the facts of a particular case." 10. Circumstantial flexibility, one additional or different fact may make a world of difference between conclusions in two cases. Disposal of cases by blindly placing reliance on a decision is not proper". 88. That brings us to the second issue, which relates to the effect of the warning about Schedule H drug. It is the contention of the advocates for the assessees that the notifications make no reference nor prescribes restrictions with reference to the Schedule H or any other provision of the Drugs and Cosmetics Act, 1940 or the rules framed thereunder. Only effect of the coverage by Schedule H drug would be that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and that they are mixed with the IV Fluids essentially for the purpose of convenience to the doctors, who may not have to bother about administering those drugs separately. It is a matter of convenience. In other words, those medicines aren't essentially components of IV Fluids meant for sugar, electrolyte and fluid replenishment. Secondly, even in common parlance, the IV Fluids with such drugs are neither known as fluid replenishment nor are administered otherwise than on prescription by the registered medical practitioner. The two products - one meant for sugar, electrolyte and fluid replenishment and another meant for therapeutic functions are clearly distinct and distinguishable from one another and a warning about the Schedule H Drugs on the products having therapeutic prospective is the identifying mark for such differentiation. Besides, undisputedly, the fact that the Sodium Cloride and Dextros are used either to restore or to keep in balance the fluid and electrolyte in the human body, whereas the anti-biotics are procured to treat various infections in the body. The materials on record also clearly establish these facts. The warning about Schedule H drug as the contents o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... payment of excise duty on base paper or base paper board where for a legal fiction had been raised in explanation appended to the said notification. The assessee therein had taken a stand that the three layers of the carton consisted of base paper and only one layer thereof consisted of plastic coated paper. The Tribunal had denied the benefit to the assessee, without considering the import of the notification. In those background, the Apex Court had observed that the eligibility clause in relation to an exemption notification has to be given strict meaning and the notification has to be interpreted in terms of its language. It has to be given effect to. 92. The fall out of the above discussion is that with effect from 1-3-2001 the exemption benefit, which is available to the Intravenous Fluid for sugar, electrolyte and fluid replenishment, does not extend to the Intravenous Fluid comprising of medicines and drugs like, anti-bacterial, anti-biotic and anti-microbial, having therapeutic properties or functions but is restricted strictly to those meant for the sugar, electrolyte and fluid replenishment only. However, there was no such restriction as far as the period prior to 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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