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Issues: Whether saree, patta, dhoti and gamuchha fall within Entry 3 of Part-II of the Schedule to the Odisha Entry Tax Act, 1999 as textile products including cotton fabrics and ready-made garments.
Analysis: The expression in the entry was read in the context of the schedule as a whole and in the light of the different rates applicable to Part-I and Part-II. The word "including" was treated as enlarging, not restricting, the scope of "textile products". The goods were examined in their ordinary commercial sense and held to remain textile products notwithstanding their particular form or use. The interpretation favoured a wide coverage of woven fabric products and rejected the narrower reading urged by the petitioner.
Conclusion: The goods in question fall within Entry 3 of Part-II of the Schedule and are exigible to entry tax.