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3.3. Concededly, the goods were cleared, albeit, provisionally, under the 1988 Notification, on execution of a bond by the appellant pending issuance of a Customs Duty Exemption Certificate (in short 'CDEC') from the concerned authority i.e., Director General of Health Services (in short 'DGHS'). The issuance of CDEC was necessary for the purpose of the appellant, as it was one of the conditions incorporated in the 1988 Notification. CDEC was issued to the appellant on 03.04.1992. Upon issuance of a CDEC by DGHS, the Customs authority made a final assessment qua the subject goods.
3.4. The record further shows that the Assistant Director General of Health Services, on 08.07.1997, issued a notice to the appellant, whereby, it was proposed to withdraw the CDEC issued to it.
3.5. We are informed by the learned counsel for the appellant that a reply was filed to the said notice.
3.6. The record further shows that Assistant Director General of Health Services cancelled the CDEC vide order dated 25.11.1997. The reason for cancellation, apparently, was that the appellant's Diagnostics Centre, did not render free medical services to the indoor patients.
20. As per the notification, all the above three post-importation conditions should be scrupulously followed by the hospital, it being a beneficiary of the subject customs duty exemption notification. Even if one of the conditions of the notification is not followed, it then naturally follows that the importing hospital becomes ineligible to avail the duty exemption benefit.
21. Though for the purposes of this notification, M/s Arogya Scan & Research Centre is considered to be a 'Hospital', it cannot automatically lay claim to the benefit of duty exemption under Notification No.64/88-Cus., as argued by the importing hospital, unless and until the Hospital satisfies all the conditions specified in the notification. In the instant case, the DGHS has not certified the hospital as eligible to avail the notification benefit by withdrawing the CDEC. As it stands, the hospital does not have a valid CDEC which is as essential qualification for the hospital to avail the notification benefit. Without the acquisition of a CEDC issued by DGHS, I find that the hospital has disqualified itself from availing the benefit of duty exemption in terms of the subject notification. ..... 13.6. A perusal of the said observations would show that, clearly, the appellant, if, nothing else, has not been able to meet the third condition, which required the appellant to provide treatment, which could only be Diagnostic facility, on reasonable charges to patients, based on their financial status or otherwise. As noted by the Commissioner, the affidavit filed by the appellant was, clearly, silent on this aspect of the matter. To our minds, the conditions stipulated in the Notification for grant of exemption, as is well settled, have to be strictly adhered to, and if, any of the conditions are not fulfilled, the person seeking exemption from customs duty cannot be extended that benefit, as such like Notifications are issued by the Central Government in exercise of the powers under Section 25 of the Act, which vest authority to grant exemption only in public weal.
15. This brings us to the other argument of the Appellant, which is, that, since, the 1988 Notification was rescinded by virtue of 1994 Notification, and therefore, no liability would befall on the appellant, according to us, this is an argument, which is misconceived.

15.1. As noticed hereinabove, this submission was predicted on the judgment of the Division Bench of this Court rendered in Seahorse Hospitals Ltd. case. A close perusal of the said judgment would show that the matter related to cancellation of the CDEC by the DGHS. The writ petitioner, in that case, being aggrieved by the fact that the cancellation of the CDEC had been brought about without being given a proper opportunity for production of documents, assailed it, by filing a writ petition in this Court. A Single Judge of this Court, allowed the writ petition by judgment dated 05.12.2006. Being aggrieved, the Union of India preferred an appeal. The Division Bench, inter alia relying upon the judgment of this Court in Apollo Hospital Enterprises Vs. Union of India, 2001 (133) E.L.T. 58 (Mad.), came to the conclusion that, once, the 1988 Notification had been withdrawn by the 1994 Notification, the concerned authority, i.e., DGHS, could not cancel the CDEC on the ground that the writ petitioner had not complied with the conditions for the subsequent period, i.e., 1994 to 1998. This is clear, upon pursuing the following observations made in paragraph 18 of the judgement :