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Issues: Whether, for embroidery machines having two rollers, the duty liability under Rule 96ZI was to be computed on the basis of the length of both rollers or only on the basis of one roller as the metre length.
Analysis: The issue was treated as already settled by earlier Tribunal decisions on the same statutory scheme. Those decisions held that Rule 96ZI did not define "meter length" until the 1998 amendment and that the expression had to be understood in line with the Board's clarification, namely the length of one roller only, even where the machine had two rollers. The reasoning accepted that the departmental demand on the basis of double roller length was inconsistent with the settled interpretation of the rule and the contemporaneous clarification.
Conclusion: The duty was to be computed on the basis of the length of one roller only, not both rollers, and the issue was decided in favour of the assessee.
Ratio Decidendi: In the absence of a contrary statutory definition, "meter length" under Rule 96ZI is to be construed as the length of one roller of the embroidery machine, even if the machine has two rollers.