Plain-language reading of schedule entries limited development rebate for woollen hosiery to the residuary rate, not the higher special rate.

A tariff or schedule entry that qualifies a series of goods by a descriptive condition must be read as a whole on its plain language. On that construction, the words "made wholly or mainly of cotton" governed the entire entry in item 32, including hosiery and rope, and could not be confined only to cotton yarn. The entry therefore did not extend to woollen hosiery, and the assessee was entitled only to the residuary 15% development rebate rather than the 25% rate under the special schedule item.

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Issues: Whether machinery used for manufacturing woollen hosiery for export entitled the assessee to development rebate at 25% under section 33(1)(b)(B)(i)(b) read with item 32 of the Fifth Schedule to the Income-tax Act, 1961, or only to the residuary rate of 15%.

Analysis: Item 32 covers textiles made wholly or mainly of cotton, including cotton yarn, hosiery and rope. On a plain reading, the qualifying words "made wholly or mainly of cotton" govern the entry as a whole, including hosiery and rope. A construction separating "cotton" only from "yarn" would make the reference to "jute rope" in the next entry redundant. The entry therefore cannot be extended to woollen hosiery.

Conclusion: The assessee was not entitled to 25% development rebate under item 32 of the Fifth Schedule and was entitled only to 15% development rebate under the residuary provision.

Ratio Decidendi: Where a tariff or schedule entry qualifies the entire series of goods by a descriptive condition, the entry must be read as a whole on its plain language, and a construction that renders adjacent entries redundant is impermissible.

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