UNION OF INDIA vs M/S. N.S. RATHNAM & SONS

The Supreme Court upheld the validity of Notifications Nos. 102/87-CE and 103/87-CE, which exempted excise duty on iron and steel scrap obtained from ship breaking, conditional upon the payment of customs duty at a specified rate under Section 3 of the Customs Tariff Act, 1975. The Court found that excluding those who paid customs duty at a lesser rate was arbitrary and violated Article 14 of the Constitution. Consequently, the Court affirmed the Division Bench's ruling that all categories of customs duty payers should benefit from the exemption.