Woollen goods exemption conditions must be met cumulatively; soft waste beyond the limit defeats the benefit.

Exemption notifications for woollen goods were construed as imposing separate and cumulative batch-wise conditions: the shoddy content had to be obtained by garnetting or pulling, virgin wool could not exceed the prescribed limit, soft wool could not exceed the stated limit, and the total wool content had to satisfy the minimum requirement. "Shoddy" was read narrowly to mean wool made from rags, tailor cuttings and hard wastes, so soft waste did not qualify. The exemption was therefore available only when each condition was independently met for the relevant batch, and the prior appellate order was set aside for fresh verification and assessment on that basis.

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Issues: Whether the exemption notifications covering woollen goods required, for each batch, that the minimum shoddy content obtained by garnetting or pulling should be not less than 50 per cent, the virgin wool content should not exceed 5 per cent, the soft wool content should not exceed 15 per cent, and the total wool content should meet the prescribed minimum, so as to qualify for exemption.

Analysis: The governing notifications were read as laying down separate and cumulative conditions for exemption. The expression "shoddy" was construed to mean wool obtained by garnetting or pulling of rags, tailor cuttings and hard wastes, and soft waste was held not to answer that description. The trade notices were treated as supporting the view that soft wool waste beyond the stated limit could not be permitted. On that construction, the benefit of the exemption was available only where each prescribed condition was independently satisfied for the batch in question.

Conclusion: The exemption was available only if all the stipulated conditions were separately complied with; the goods were not entitled to the benefit merely because some other fibre was used or absent.

Final Conclusion: The prior appellate order was set aside and the matter was sent back for verification of records and fresh assessment in accordance with the declared interpretation.

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