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3.6 Reliance was also placed upon the decision of the Supreme Court in the case of Ralson (India) Ltd. v. Commissioner of Central Excise, Chandigarh-1, 2015 (319) ELT 234 (S.C.) ➳ (2015) 14 SCC 679, wherein the court held thus:

"8. We may point out here that the issue has not come up before this Court for the first time. In the case of W.P.I.L. Ltd. v. Commissioner of Central Excise, Meerut, U.P. , 2005 (181) E.L.T. 359 (S.C.), this Court was concerned with almost identical fact situation, albeit in relation to the product known as 'Part of Power Driven Pumps'. The power driven-pumps also were similarly exempted which exemption was available to manufacturers since 1978. In the Notification No.69/94- C.E., dated 1-3-94 whereby exemption qua 389 earlier notifications was rescinded, the notification in respect of the part of power-driven pumps was also included as rescinded. Thereafter, the same item was again exempted by Notification No.95/94-C.E. issued on 25-4- 1994. In this manner, insofar as parts of power driven pumps are concerned, there was no exemption in respect thereof for the period from 1-3-94 to 24-4-1994.
"16. In view of the consistent policy of the Government of exempting parts of power driven pumps utilized by the factory within the factory premises, it could not be said that while issuing Notification No.46/94 of March 1, 1994, the exemption in respect of said item which was operative was either withdrawn or revoked. The action was taken only with a view to rescinding several notifications and by issuing a composite notification. The policy remained as it was and in view of demand being made by the Department, a representation was made by the industries and on being satisfied, the Central Government issued a clarificatory Notification No.95/94 on April 25, 1994. It was not a new notification granting exemption for the first time in respect of parts of power driven pumps to be used in the factory for manufacture of pumps but clarified the position and made the position explicit which was implicit."

35. In W.P.I.L. Ltd. v. Commissioner of Central Excise, Meerut. UP., (supra), the Supreme Court was dealing with a case where exemption in respect of power-driven pumps was also available to the manufacturers since 1978. In Notification No. 64/94-CE dated 1.3.1994 whereby exemption qua 389 earlier notifications was rescinded, the notification in respect of the part of power-driven pumps was also included as rescinded. Thereafter, the same item was again exempted by C/SCA/20756/2018 JUDGMENT Notification No. 95/94-CE issued on 25.4.1994. In this manner, insofar as parts of power-driven pumps are concerned, there was no exemption in respect thereof for the period from 1.3.1994 to 24.4.1994. The assessee in that case took the same plea by arguing that since the decision of the exemption vide Notification dated 1.3.1994 was an inadvertent error and the Government realising this mistake had reintroduced the exemption it will be treated as only corrective and clarificatory in nature. This contention was accepted by the court in the aforesaid judgment holding that even during the period from 1.3.1994 to 24.4.1994, the manufacturers of parts of power- driven pumps shall continue to get the exemption. The court held thus:

"16. In view of the consistent policy of the Government of exempting parts of power-driven pumps utilised by the factory within the factory premises, it could not be said that while issuing Notification No. 46/94 of 1.3.1994, the exemption in respect of said item which was operative was either withdrawn or revoked. The action was taken only with a view to rescinding several notifications and by issuing a composite notification. The policy remained as it was and in view of demand being made by the Department, a representation was made by the industries and on being satisfied, the Central Government issued a clarificatory Notification No. 95/94 on 25-4-1994. It was not a new notification granting exemption for the first time in respect of parts of power-driven pumps to be used in the factory for manufacture of pumps but clarified the position and made the position explicit which was implicit."