Ordinary commercial meaning controls tax exemptions: razors are not knives, so their turnover was not exempt.

Expressions in a tax exemption notification must be construed in their ordinary and commercial sense as understood in trade and by consumers. Applying that rule, razors were held not to be knives, because the two articles are not interchangeable: knives are ordinarily used for cutting items such as food, while razors are used for shaving or cutting hair. The exemption could not be enlarged by analogy or strained interpretation. Accordingly, turnover from razors did not qualify for exemption under the notification, and the reference was answered in favour of the Revenue.

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Issues: Whether razors are knives within the meaning of Notification No. ST-911/X dated 31st March, 1956, so as to entitle their turnover to exemption from tax.

Analysis: The term used in the exemption notification was not defined in the U.P. Sales Tax Act or the rules. The expression had therefore to be understood in its ordinary and commercial sense, as commonly understood in trade and by consumers. Although a knife and a razor may both be cutting instruments in a broad dictionary sense, they are not interchangeable articles. Their use is different: a knife is used for cutting articles such as vegetables, fruits and meat, whereas a razor is used for shaving or cutting hair. An exemption notification cannot be extended by analogy or by resort to technical or strained meanings where the language is clear.

Conclusion: Razors are not knives within the notification and their turnover is not exempt from tax.

Final Conclusion: The reference was answered against the assessee and in favour of the Revenue on the scope of the exemption notification.

Ratio Decidendi: Expressions in a tax exemption notification must be construed in their ordinary and commercial sense, and an exemption for one article cannot be extended by analogy to a different article merely because both are broadly similar in nature.

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