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Issues: Whether toughened safety glass, including windscreen, door screen, side screen and back screen, fell within the expression "glass and glass wares including optical glass in all forms" for the purpose of the exemption under Section 4-B of the U.P. Sales Tax Act, 1948.
Analysis: The relevant notification granted exemption for raw materials used in manufacturing the notified goods, and the entry covered "glass and glass wares including optical glass in all forms". The decisive expression was "in all forms", which broadened the scope of the entry. The articles manufactured by the assessee were admittedly made of glass, and the use of the broader expression meant different manifestations of the same commodity were included. The later notification specifically excluded ornamented or cut glass bangles, but did not exclude the assessee's products. The Court also applied the settled principle that tax entries must ordinarily be construed in their popular or common parlance sense, but held that the High Court erred by reading the earlier precedent without giving effect to the widening words "in all forms" and by effectively adding words to the notification.
Conclusion: The articles manufactured by the assessee were covered by the entry and were entitled to the benefit of Section 4-B. The High Court's view was set aside and the Tribunal's order restored, in favour of the assessee.