Common parlance meaning of "sheet" extended notification benefit to greenhouse shade nets, despite Revenue's narrower tariff objection.

Woven plastic shade nets imported for greenhouse use were treated as covered by the notification entry for "ultra violet retardant fibre glass/plastic sheets" because "sheet" was not specially defined and had to be read in common parlance and ordinary dictionary sense. The majority accepted that a woven fabric or net could still answer that description, particularly where the goods were certified for greenhouse application, and rejected the Revenue's narrower distinction based on air permeability. The dissent considered the entry confined to plastic sheets and not to woven shade nets under a different tariff heading. The goods were held eligible for the notification benefit, and the Revenue's appeal was dismissed.

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Issues: Whether woven shade nets imported for greenhouse use were covered by Sr. No. 144 in List 8 of Customs Notification No. 11/97 as "Ultra violet retardant fibre glass/plastic sheets".

Analysis: The majority held that the expression "sheet" was not defined in the notification or in the relevant tariff context and had to be understood in common parlance and by ordinary dictionary meaning. On that basis, a woven fabric or net of plastic could still answer the description of a sheet, particularly where the goods were certified as required for greenhouse application. The majority rejected the Revenue's narrow distinction based on air permeability and held that the notification description was wide enough to include the imported goods. The dissenting view was that the notification was specific and confined to plastic sheets, not woven shade nets classifiable under a different tariff heading.

Conclusion: The imported goods were held eligible for the notification benefit and the Revenue's appeal was dismissed.

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