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Issues: Whether aluminium bars, though not in crude form, were covered by Notification No. 43/75 and Item 27 of the Schedule to the Central Excises and Salt Act, 1944 so as to qualify for the exemption.
Analysis: The notification and Item 27 employed inclusive language referring to aluminium in any crude form and also specifically including ingots, bars, blocks, slabs, billets, shots and pellets. On a plain reading, the inclusive wording showed that the reference to crude form extended to the listed products even if they were not themselves in crude form. The Court distinguished the earlier inclusive-definition case relied upon by the Revenue as turning on the particular statute there under consideration and not controlling the present notification.
Conclusion: Aluminium bars were covered by the notification and the exemption was available; the appeal therefore failed.
Ratio Decidendi: Where an exemption notification uses inclusive language that expressly enumerates particular forms of a commodity, those specified forms are covered even if they do not independently answer the description of crude form.