Jute canvas fell outside the textile exemption because the notification excluded jute cloth and the goods remained taxable.

Canvas cloth made wholly of jute was held to fall outside the exemption for textile canvas because the notification expressly excluded hessian or jute cloth. The court read the canvas entry consistently with that exclusion and relied on the material record, sample, and standard specification showing the goods were jute canvas, a plain-weave cloth made entirely of jute. On that construction, the commodity was treated as jute cloth and jute and hemp goods, and therefore remained taxable rather than exempt.

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Issues: Whether canvas cloth made of jute was exempt from tax under the relevant exemption notifications, or was taxable as jute cloth and jute and hemp goods.

Analysis: The disputed commodity was examined with reference to the notification entries. Although canvas cloth may, in general understanding, denote a stout cloth, the material on record showed that the goods in question were made wholly of jute. The exemption notification for textiles expressly excluded hessian or jute cloth, while the entry referring to canvas cloth had to be read in a manner consistent with that exclusion. The Court also noticed that the sample and the standard specification supported the view that jute canvas is a plain weave cloth made wholly of jute. On that basis, the expression "canvas cloth" in the exemption entry was construed as canvas cloth other than jute cloth, and the commodity was held to fall within the taxable entry for jute and hemp goods.

Conclusion: Canvas cloth made of jute was not exempt under the notifications and was liable to tax as jute cloth and jute and hemp goods.

Ratio Decidendi: Where an exemption notification expressly excludes jute cloth, canvas cloth made wholly of jute cannot be treated as exempt canvas cloth merely because it is stout or densely woven; the exclusion prevails and the commodity remains taxable.

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