Broad construction of exemption notifications can cover Vat Indigo Blue used in textile manufacture under the specified tariff entry.

A broad, inclusive reading of Serial No. 67 of Notification No. 4/2006-C.E. is required where the entry refers to tariff headings 3204 and 3809 and covers finishing agents, dye carriers and other products used in textile manufacture. A construction that confines the entry to heading 3809 alone is unsustainable because it makes the broader words redundant. The commentary states that the phrase "any kind" is wide enough to include Vat Indigo Blue under heading 3204 when used in the manufacture of textile articles, so the exemption from countervailing duty is available and the restrictive order cannot stand.

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Issues: Whether Vat Indigo Blue imported by the appellant was covered by Serial No. 67 of Notification No. 4/2006-C.E. dated 01.03.2006 so as to qualify for exemption from countervailing duty.

Analysis: The entry specified tariff headings 3204 or 3809 and covered finishing agents, dye carriers and other products and preparations used in the same factory for the manufacture of textiles and textile articles. The restrictive reading adopted by the lower authority, confining the expression to heading 3809 alone, was found unsustainable because the notification itself did not so limit the scope of the words used. A construction that made the words preceding "other products and preparations" redundant was rejected. The expression "any kind" in the notification was held wide enough to include the imported Vat Indigo Blue falling under heading 3204, especially when the goods were admittedly used in the manufacture of textile articles.

Conclusion: Vat Indigo Blue was held to be covered by Serial No. 67 of Notification No. 4/2006-C.E. and the exemption from countervailing duty was available to the appellant.

Final Conclusion: The impugned order was set aside and the exemption claim succeeded, with consequential relief to the appellant.

Ratio Decidendi: Where a notification uses broad inclusive language and specifies multiple tariff headings, the entry must be construed so as to give effect to all its words, and a good falling within one of the specified headings cannot be excluded by an artificial restrictive reading that renders the remaining expression redundant.

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