TMI Blog2019 (11) TMI 1161X X X X Extracts X X X X X X X X Extracts X X X X ..... for export purpose up to port or air port. There was no exemption for the said services if the export took place from land custom agent. The land custom station was specifically introduced in the Notification w.e.f. 01 April, 2015 by way of Amending Notification No.04/2015-ST. It is well settled law that the Notification have to be interpreted in the light of the expression used therein. The Notification No.31/2012 clearly mentions only port or air port and there is no ambiguity in the use of the said expression. If an unambiguous language stands used by the Government, legislative intent is not required to be examined. Tribunal being only an interpreter of the notification cannot rewrite the notification by introducing any extraneous w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ppellant Shri Pawan Kumar Singh, Authorized Representative for Respondent ORDER ARCHANA WADHWA Both the appeals are being disposed of by a common order as the issue involved in both of them is identical. 2. After hearing both the sides duly represented by learned advocate Shri Vineet Kumar Singh appearing on behalf of the Appellant and learned AR, Shri Pawan Kumar Singh appearing on behalf of the Revenue, we find that the appellant is exporter of writing paper, which is being manufactured by them. In terms of Notification No.31/2012-ST dated 20 June, 2012, they used the services of GTA for movement of the goods for the export purposes. Inasmuch as the expo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (1) (2) (3) 1. Service provided to an exporter for transport of the said goods by goods transport agency in a goods carriage from any container freight station or inland container depot to the port or airport, as the case may be, from where the goods are exported; or Service provided to an exporter in relation to transport of the said goods by goods transport agency in a goods carriage directly from their place of removal, to an inland container depot, a container freight station, a port or airport, as the case may be, from where the goods are exported. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... interpreted in the light of the expression used therein. The Notification No.31/2012 clearly mentions only port or air port and there is no ambiguity in the use of the said expression. If an unambiguous language stands used by the Government, legislative intent is not required to be examined. Tribunal being only an interpreter of the notification cannot rewrite the notification by introducing any extraneous words to the same. We are of the view that the land customs station having been introduced in the notification w.e.f. 14 February, 2015, it cannot be held that the exemption was effective from the original date of issuance of the notification even in respect of exports from land customs station. 7. However, we note that ..... X X X X Extracts X X X X X X X X Extracts X X X X
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