CBIC can’t modify scope of Exemption Notification
Hon’ble CESTAT stated that exemption notification is issued by Central Government in the exercise of power given under section 93 of the Finance Act, 1994. Exemption notification is approved after obtaining approval from both houses of parliament. However, no power is extended to CBIC to modify the scope of the exemption notification. Therefore, conditions attached by CBEC to exemption issued by the Central Government are illegal, unauthorized, and of no effect.