Popular and commercial meaning of cycle parts favours exemption for dynamo lighting sets under excise notification.

Cycle dynamo lighting sets were treated as "cycle parts" for exemption under the central excise notification. Because "cycle and parts thereof" was not defined, the court applied the popular and commercial meaning rather than a narrow technical construction. It relied on surrounding notifications, circulars, industry publications and trade usage showing that dynamo lamps and lighting sets were understood as bicycle components, not mere accessories. Applying the rule that a reasonable ambiguity in a taxing statute must be resolved in favour of the taxpayer, the court concluded that the lighting sets qualified as cycle parts and were entitled to exemption.

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Issues: Whether cycle dynamo lighting sets are "cycle parts" for the purpose of exemption under the relevant central excise notification.

Analysis: The expression "cycle and parts thereof" was not defined in the taxing framework, so it had to be understood in its popular and commercial sense rather than in a narrow technical sense. The surrounding governmental notifications, circulars, industry publications, and trade usage treated dynamo lamps and lighting sets as bicycle components or cycle parts, not merely as accessories. In a taxing statute, where two interpretations are reasonably possible, the interpretation favourable to the taxpayer must be preferred.

Conclusion: Cycle dynamo lighting sets were held to fall within "cycle parts" and were entitled to the exemption.

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