Ordinary meaning controls exemption interpretation as flock printing of wall-paper qualifies for excise relief.

An exemption notification must be construed according to the ordinary and generally understood meaning of the relevant expression, not by an unsupported restrictive reading. Applying that approach, flock printing of P.V.C.-coated wall-paper was treated as flock printing within the process understood in trade usage, and the activity fell within Excise Exemption Notification No. 62 of 1976. The Court rejected the view that the process was outside the notification merely because it was not characterised as printing of colour in a narrower sense. The exemption was therefore upheld and the benefit remained available to the respondent.

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Issues: Whether flock printing of P.V.C. coated wall-paper amounted to the kind of printing of colours contemplated by Excise exemption Notification No. 62 of 1976, so as to entitle the respondent to exemption.

Analysis: The Appellate Collector had accepted, on the basis of personal observation of the process and expert opinion, that the activity conformed to flock printing and fell within the understanding of the process reflected in the trade notice. The reviewing authority, though proceeding on the footing that the process was flock printing, denied exemption on the view that it was not printing of colour within the notification. The Court held that there was no material to justify that restrictive construction, and that the notification had to be read in the sense in which the relevant expression was generally understood.

Conclusion: The process was covered by the exemption notification and the respondent was entitled to the benefit of exemption.

Final Conclusion: The appeal failed, and the order granting exemption to the respondent was sustained.

Ratio Decidendi: An exemption notification must be construed according to the ordinary and generally understood meaning of the relevant expression, and a denial of exemption cannot rest on an unsupported restrictive interpretation of the process in question.

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