Exemption for village industry goods turns on the broad reading of "and/or" in the recognition-based notification.

Soap manufactured by a unit recognised by the Khadi and Village Industries Commission was treated as eligible for exemption under S.R.O. No. 287/64, because the notification used the expression "manufactured and/or sold" by recognised institutions or persons. That wording was read to cover three categories: goods manufactured by a recognised body, goods sold by it, and goods both manufactured and sold by it; it could not be narrowed by substituting "and" for "and/or". A later objection based on the period of recognition was not considered, as it was a factual plea raised for the first time after the matter had passed through the lower authorities.

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Issues: Whether soap manufactured by a unit recognised by the Khadi and Village Industries Commission was entitled to exemption under S.R.O. No. 287/64 even if the goods were not also sold by a recognised institution.

Analysis: The notification granted exemption for products of village industries where the goods were manufactured and/or sold by institutions or persons recognised by the Khadi and Village Industries Commission or the Kerala Khadi and Village Industries Board. The expression "and/or" was construed to cover three categories of goods: goods manufactured by such institutions, goods sold by them, and goods both manufactured and sold by them. The wording of the notification could not be re-drafted to substitute "and" for "and/or". The later objection regarding the period of recognition was not entertained because it was a factual plea raised for the first time and had not been urged before the authorities below.

Conclusion: Exemption was available if the goods were either manufactured or sold by a recognised institution, and the claim for exemption succeeded.

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