Industrial unit interpretation supports exemption for a self-contained manufacturing section within a larger factory complex.

An exemption notification that used both "factory" and "industrial unit" was construed as giving each term an independent meaning. "Unit" was read as a separate or isolable part of a larger whole, and "industrial" as relating to productive industry. On that construction, a distinct plant and building devoted exclusively to varnish manufacture could qualify as an industrial unit even though it formed part of a larger factory complex, and the exemption was available to that self-contained manufacturing section.

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Issues: Whether the separate plant and building within the petitioners' factory, used exclusively for manufacturing varnishes, constituted an "industrial unit" for the purpose of the exemption notification.

Analysis: The notification used both the expressions "factory" and "industrial unit", showing that they were intended to bear different meanings. The expression "unit" denotes a separate or isolable part of a larger whole, while "industrial" relates to industry or productive labour. On that construction, a distinct plant and building exclusively devoted to varnish manufacture could answer the description of an industrial unit, even though it formed part of a larger factory complex.

Conclusion: The varnish plant and building were an industrial unit, and the petitioners were entitled to the exemption.

Ratio Decidendi: Where a fiscal notification uses both "factory" and "industrial unit", the latter must be given an independent meaning as a separate or isolable industrial part of a larger complex, and a distinct self-contained manufacturing section may qualify for the exemption.

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