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Issues: Whether garments stitched by tailors on individual customer orders could be treated as ready-made garments liable to confiscation and excise control for want of a Central Excise licence.
Analysis: The lower authorities proceeded on the assumption that the seized garments were ready-made garments manufactured with the aid of an electric iron. In revision, the record did not disprove the petitioners' case that they were only tailors making garments on customers' orders. On that footing, and in the absence of evidence negating that version, the benefit of doubt was extended to the petitioners. Garments made to order for individual customers were held not to answer the description of ready-made garments merely because they were pressed with an electric iron.
Conclusion: The garments were not liable to be treated as ready-made garments for excise purposes, and the confiscation was set aside in favour of the petitioners.