Broad exemption construction for captive-use textile printing goods upheld for nickel cylinders and printing frames.

Exemption notifications for textile printing were construed broadly to cover nickel cylinders and printing frames manufactured for captive use, because the Board's clarification treated printing frames, design screens and cylinder screens as not materially different for that purpose. Trade practice and the earlier understanding that printing frames and design cylinders were essentially the same supported that reading. On that basis, the later notification was applied to the appellant's goods, and the goods were treated as exempt from duty.

---

---

Issues: Whether nickel cylinders and printing frames manufactured for captive use in printing of textiles were entitled to duty exemption.

Analysis: The exemption notifications and the Board's clarification treated printing frames, design screens and cylinder screens as not materially different for the purpose of captive use in textile printing. The Tribunal also relied on the understanding reflected in trade practice and on the earlier view that printing frames and design cylinders were essentially the same for exemption purposes. On that basis, the expression used in the later exemption notification was read broadly to cover the goods manufactured by the appellant.

Conclusion: The goods were covered by the exemption and were not liable to duty.

---