Restrictive interpretation of "includes" under the DEPB Scheme excludes fabricated aluminium grills from extruded aluminium products.

The expression "extruded aluminium products" in Item 7 of Product Code 61 of the DEPB Scheme was construed restrictively in light of the text and context of the entry, including its reference to pipes and tubes. The Court held that "includes" operated as a limiting word in that scheme, covering only extruded aluminium products simpliciter and standardized items such as pipes and tubes, not further fabricated end-products. Because aluminium grills were manufactured by fabricating extruded aluminium sections, they were not identical to extruded aluminium products. The goods therefore did not qualify for DEPB benefit.

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Issues: (i) Whether aluminium grills fabricated from extruded aluminium sections fall within the expression "extruded aluminium products" in Item 7 of Product Code 61 of the DEPB Scheme.

Analysis: The expression "extruded aluminium products" was construed in the context of the DEPB Scheme and the relevant entry, which expressly includes "pipes and tubes". The Court held that the word "includes" in that setting was used restrictively, indicating that the entry covered extruded aluminium products simpliciter and only such standardized products as pipes and tubes, not further fabricated end-products. Since the assessee itself manufactured aluminium grills by fabricating extruded aluminium sections, the goods were not identical to extruded aluminium products. The Court applied the principle that interpretation of inclusive language depends on text, context, and object, and that "includes" may operate as a word of limitation where the scheme so requires.

Conclusion: Aluminium grills fabricated from extruded aluminium sections do not qualify as "extruded aluminium products" under Item 7 of Product Code 61, and the assessee is not entitled to the DEPB benefit.

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