- (1.) The question to be decided in this appeal is whether the appellant is entitled to the benefit of the concessional rates of levy of excise duty under Notification No. 193/82 dated 11-6-1982 for the entire production during May to September 1982.
(2.) Before the said notification (hereinafter referred to as "the second notification") came into force, an earlier notification being Notification No. 132/82 dated 21.04.1982 had granted certain concessional rates of excise duty but, by virtue of para 4 of that notification, excluded sugar factories from the purview of the benefit.
(3.) The appellant is a sugar factory. Because the second notification extended the benefit to sugar factories, the appellant put in a rebate claim before the Excise Authorities in respect of its production from May to September 1982. This was denied by the Excise Authorities on the ground that the second notification had only come into effect on 11.06.1982.;