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1 - 2 of 2 (0.60 seconds)Novopan India Ltd., Hyderabad vs Collector Of Central Excise And ... on 14 September, 1994
7.Appellant's counsel submitted that if due stress is
given to the conditions, what the notification means is that
exemption is available to the entire quantity of admixture
of the vegetable product produced out of rice bran oil, the
only condition being that the content of rice bran oil
should be more than 1 % of the total, in any consignment,
and such interpretation of the notification is equally
possible. We are of the view that such a construction is
not possible. Even assuming that it is so, in the case of
an ambiguity or doubt regarding an exemption provision in a
fiscal statute, the ambiguity or doubt will be resolved in
favour of the Revenue and not in favour of the assessee.
The matter is concluded by a recent decision of a three-
member Bench of this Court in Novopan India Ltd. v.
Collector of Central Excise and Customs1. On this ground as
well, the appellant is not entitled to any relief. The
appeals are dismissed with costs.
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