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Issues: Whether sportswear such as tennis shirts, jerseys, lowers, T-shirts, pullovers, sports caps, wrist bands, jogging suits and track suits are taxable as ready-made garments or as goods for indoor or outdoor games or sports under the relevant trade tax notifications.
Analysis: The expression "goods for indoor or outdoor games or sports" was held to denote articles with which games or sports are actually played, such as balls, bats, rackets and similar equipment, and not garments merely worn by sportsmen. The entry was treated as having a restricted meaning, reinforced by the surrounding wording and the illustrative inclusions in the notification. Sportswear, even if specially designed for players and sold by dealers in sports goods, remained garments in commercial and ordinary understanding. The competing entry for ready-made garments was considered wide enough to cover such items, and the absence of a separate sportswear entry supported taxation under that category.
Conclusion: The sportswear in question was correctly assessed as ready-made garments and not as goods for indoor or outdoor games or sports.
Final Conclusion: The revisions failed because the contested items fell within the garments entry, leaving the revenue assessment undisturbed.
Ratio Decidendi: Where a tariff or notification entry for games and sports goods is contextually restricted to equipment used to play the sport, sportswear remains classifiable as garments unless a separate entry specifically covers it.