Specific entry prevails over residual description in exemption notifications: Sodium Hypochlorite solution was not treated as Bleach liquor.

A taxing exemption notification separately listed Sodium Hypochlorite at one entry with a captive-consumption condition, while "Bleach liquor" appeared later as a different and residual description. On that construction, Sodium Hypochlorite solution could not be read into the later "Bleach liquor" entry, and the specific earlier entry could not be ignored. A comparison with an earlier notification was considered unhelpful because it did not separately enumerate Sodium Hypochlorite. The Tribunal also relied on chemist opinion and a Board circular to support the narrower reading, and concluded that Sodium Hypochlorite solution was not covered by the exemption as "Bleach liquor."

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Issues: Whether Sodium Hypochlorite solution was eligible for exemption as "Bleach liquor" under Sl. No. 26 of the Table annexed to Notification No. 7/94-C.E. dated 1-3-94.

Analysis: The notification contained a separate entry for Sodium Hypochlorite at Sl. No. 2 and attached a captive-consumption condition to that entry, while "Bleach liquor" appeared later at Sl. No. 26 without such condition. The separate enumeration of Sodium Hypochlorite showed that the later entry for "Bleach liquor" was residual and was not intended to include Sodium Hypochlorite solution. The comparison with Notification No. 195/86-C.E. was held to be unhelpful because that notification did not contain a separate entry for Sodium Hypochlorite. The Tribunal also relied on the chemist's opinion and Board circular to support the view that "Bleach liquor" did not cover Sodium Hypochlorite solution under the notification in question.

Conclusion: Sodium Hypochlorite solution was not covered by "Bleach liquor" under Sl. No. 26 of Notification No. 7/94-C.E. and was not eligible for exemption on that basis.

Ratio Decidendi: Where a taxing exemption notification separately lists a commodity under one entry, a later residual entry for a different description cannot be construed to include that commodity, especially when the specific entry carries its own conditions for exemption.

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