Common parlance test governs excise tariff classification; non-woven woollen felts fall outside "woollen fabrics" entry.

Tariff classification under excise law must be determined in the commercial or common parlance sense, not by a purely scientific or technical reading. On that approach, the expression "woollen fabrics" in Entry 21 of the First Schedule to the Central Excises and Salt Act was understood as referring to woven material as popularly known, reinforced by the entry's association with items such as blankets, rugs and shawls. Non-woven felts made from woollen fibres did not fit that popular description and were therefore outside the entry. The excise levy was accordingly unsustainable and the assessee succeeded.

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Issues: Whether non-woven felts manufactured from woollen fibres were "woollen fabrics" within Entry 21 in the First Schedule to the Central Excises and Salt Act, 1944.

Analysis: Classification under excise tariff entries is to be understood in the commercial sense rather than in a purely scientific or technical sense. Reading Entry 21 as part of the group of fabric entries, the use of the expression "woollen fabrics" indicated woven material as popularly understood, and the specific inclusion of items such as blankets, rugs and shawls showed that the entry was not intended to extend to non-woven felt products. On that understanding, the respondent's products did not answer the description of woollen fabrics.

Conclusion: The products were not woollen fabrics under Entry 21, and the levy of excise duty was not sustainable; the decision was in favour of the assessee.

Ratio Decidendi: Tariff expressions relating to goods must be construed in their commercial/common parlance sense, and a product will fall within the entry only if it answers that popular commercial description.

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