Contextual reading of "industrial undertaking" limits tax exemption to the paper unit, not the whole composite concern.

A taxing exemption notification using the expression "industrial undertaking" in relation to paper, paper pulp and paper products was construed contextually by reference to the relevant manufacturing unit. Because the term was not defined in the governing enactment, it was given its ordinary trade meaning within the scope of the levy and exemption. On that basis, the exemption could not be extended to all units of a composite concern at the same location. It was confined to the paper and paper products undertaking, and not to the sugar mill or other units. The Revenue's challenge failed and the exemption was sustained.

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Issues: Whether, for the purpose of exemption from cess under the relevant notification, the expression "industrial undertaking" referred only to the paper/paperboard manufacturing unit or extended to the entire integrated concern including the sugar mill.

Analysis: The expression "industrial undertaking" was not defined in the governing enactment, and the notification was issued in the context of cess on paper, paper pulp and paper products. The relevant expression was therefore construed in its ordinary trade sense and in the context of the manufacturing unit to which the levy and exemption related. On that construction, it would be incorrect to aggregate all industries belonging to the same concern at the same location when the exemption was intended to operate with reference to the paper unit alone.

Conclusion: The exemption had to be confined to the undertaking manufacturing paper and paper products, and not to the sugar mill and other units taken together. The Revenue's challenge failed.

Final Conclusion: The impugned order granting the exemption on the basis of the paper-manufacturing unit was sustained, and the Revenue appeal stood rejected.

Ratio Decidendi: Where a taxing exemption notification uses the expression "industrial undertaking" in relation to a specific manufacturing activity, the expression is to be construed contextually and as referring to the relevant industrial unit, not to all units of a composite concern.

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