Plain-language reading of exemption notification denied excise relief for unengraved copper cylinders used in textile mills.

The exemption notification for engraved copper rollers or cylinders used in the textile industry was construed according to its plain language. The High Court held that the word "or" did not broaden the entry to cover all copper cylinders used in textile mills, because the goods still had to be engraved for the exemption to apply. As the petitioners' cylinders were used in the textile industry but were not engraved, the statutory condition was not met and exemption from excise duty was denied.

---

---

Issues: Whether copper cylinders manufactured for use in the textile industry were entitled to exemption from excise duty under the notification for "engraved copper rollers or cylinders for use in textile industry".

Analysis: The exemption entry was construed according to its plain language. The notification exempted copper rollers or cylinders only when they were engraved and used in the textile industry. The use of the word "or" did not enlarge the exemption to all copper cylinders used in textile mills, because such a reading would ignore the requirement that the goods be engraved and would distort the entry's natural meaning. As the petitioners' cylinders were copper cylinders used in the textile industry but not engraved, the condition for exemption was not satisfied.

Conclusion: The exemption was not available to the petitioners, and their challenge failed.

---