Plain meaning of tax entry prevails: no stainless steel restriction could be read into the later notification.

A tax notification entry must be read according to its plain language, and no limiting words can be added where the wording is clear and unambiguous. The Delhi HC held that entry No. 27 of the second notification dated 21 October 1975 covered safety razor blades, surgical instruments, and parts of industrial machinery and plant without confining them to stainless steel goods. The earlier exclusion of similar stainless steel items from another notification could not be used to import a stainless steel restriction into the later entry. On that construction, the goods fell within the entry and were taxable at 5%.

---

---

Issues: Whether entry No. 27 of the second notification dated 21st October, 1975, covered all safety razor blades, surgical instruments and parts of industrial machinery and plant at 5% tax without restricting the entry to goods made of stainless steel.

Analysis: The entry was held to be clear and unambiguous on its plain language. Where the words used by the Legislature are explicit, effect must be given to them as they stand, and no words can be read into the entry to supply a limitation not expressed. The fact that similar goods made of stainless steel had been excluded from entry No. 29 of the first notification did not justify importing a stainless steel condition into entry No. 27 of the second notification. The proper approach was to construe the notification on its own language, without adding qualifying words or treating the earlier exclusion as controlling the later entry.

Conclusion: Entry No. 27 of the second notification applied to all such goods, whether made of stainless steel or not, and the sales were taxable at 5% in the assessee's favour.

Ratio Decidendi: A clear tax entry must be given its ordinary meaning, and a court cannot add restrictive words to a notification merely because a similar item was excluded from another entry.

---