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Issues: Whether wood-wool is a product of timber liable to tax at 6% under the applicable notification, or an unclassified item taxable at 8%.
Analysis: Wood-wool is obtained by grinding timber or wood and is produced through an action, operation, or work on the raw material. The expression "product" in the relevant notification is of wide import and covers anything produced from timber or wood by a physical process, not merely something that grows naturally from it. The court relied on earlier decisions construing "product" to include goods obtained from timber by processing, cutting, joining, or similar operations, and also on the Supreme Court's understanding that "product" means anything produced or obtained as a result of some operation or work.
Conclusion: Wood-wool is a product of timber or wood and is taxable at 6% under the notification, not as an unclassified item at 8%.
Ratio Decidendi: A commodity obtained from timber or wood by processing, grinding, cutting, or other action or operation falls within the expression "product of timber or wood" where the governing notification uses "product" in its broad and ordinary sense.