Non-woven glass wool fabric qualified for exemption because the notification's wording did not limit serial number 10 to woven fabrics.

Glass wool mat/felt was treated as non-woven fabric on the basis of its manufacturing process, technical literature and test reports. Serial number 10 of Notification No. 52/86-C.E. did not limit coverage to woven fabrics, and the notification had to be read as a whole according to its language. Serial number 11 concerned glass fabrics impregnated, coated, covered or laminated with plastics or varnish, so it did not govern this product. The product therefore fell under serial number 10 and qualified for exemption.

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Issues: Whether glass wool mat/felt, held to be non-woven fabrics, was covered by serial number 10 of Notification No. 52/86-C.E. dated 10-02-1986 and entitled to exemption, or fell under serial number 11 of the notification.

Analysis: The product was found, on the basis of manufacturing process, technical literature and test reports, to be non-woven fabrics. Serial number 10 of the notification did not distinguish between woven and non-woven fabrics, while serial number 11 applied to glass fabrics impregnated, coated, covered or laminated with plastics or varnish. Since the notification had to be read as a whole and exemption provisions were to be construed in a manner consistent with their language, the absence of any woven-only limitation in serial number 10 meant that non-woven fabrics were also covered.

Conclusion: The product was covered by serial number 10 of Notification No. 52/86-C.E. and the assessees were entitled to the exemption.

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