Claim of refund rejected as exemption notification to be interpreted strictly

Assistant Commissioner Of Customs Vs Kurian Abraham (P) Ltd. (Madras High Court) Conclusion: Exemption notification has to be interpreted stricto sensu. No external aids can be brought in to interpret an exemption notification. If  assessees, who claim benefit of exemption notification, fail to fulfil any one of the conditions contained therein, the benefit cannot be extended. Courts have to read the exemption notification as such without substituting the words or phrases. On a reading of Notification No.102/2007, it was found that nowhere there was indication that it was a supersession of an...