Generic exemption wording covers all varieties of the described commodity unless the notification expressly limits it.

An exemption notification describing goods as "silk yarn" was construed in its natural and ordinary sense because the entry did not qualify the term with "pure", even though that qualifier appeared elsewhere in the same notification. On that construction, the expression was held to include both pure silk yarn and artificial silk yarn. The commodity therefore qualified for exemption, and the challenge to the Tribunal's view failed. The governing principle is that a commodity description used in generic form in an exemption notification covers all varieties ordinarily encompassed by that description unless the text expressly limits it.

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Issues: Whether the expression "silk yarn" in the exemption notification includes artificial silk yarn, so as to exempt the commodity from tax.

Analysis: The notification used the expression "silk yarn" without qualifying it by the word "pure", although the word "pure" was used in the same entry with other commodities. The natural and ordinary meaning of the expression was therefore applied. On that construction, "silk yarn" was held to be used in a generic sense covering both pure silk yarn and artificial silk yarn. Support was also drawn from a similar view taken by the Orissa High Court on the same expression.

Conclusion: The expression "silk yarn" includes artificial silk yarn. The commodity was entitled to exemption and the challenge to the Tribunal's view failed.

Ratio Decidendi: Where an exemption notification uses a commodity description in generic form without qualification, the expression must be given its ordinary meaning and includes all varieties covered by that description unless the text expressly restricts it.

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