Goods retain their statutory identity as sheets despite rolling for transport, preserving exemption eligibility.

Insole and midsole sheets imported in rolled form for loading and transport retained their character as "sheets" for exemption purposes. The true meaning of the notification description controlled the dispute, and the goods were shown to be sold and bought as sheets rather than as films or sheetings. Rolling for convenience did not change their statutory or commercial identity, and the Revenue failed to prove that the goods had ceased to be sheets or were otherwise taxable. The exemption was therefore available, and the prior plastic-film distinction did not apply on these facts.

---

---

Issues: Whether insole and midsole sheets imported in rolled form for loading and transportation lost their character as "sheets" and thereby ceased to qualify for exemption under the notification.

Analysis: The dispute turned on the true meaning of the description in the exemption notification. The goods were shown to be sheets imported in running length and rolled only for safe transport and handling. The Revenue did not adduce evidence to prove that the goods were anything other than sheets, and the burden to establish taxability rested on the Revenue. The earlier distinction drawn in the cited plastic-film case did not control the present facts, because that case dealt with goods commercially known as films, whereas the present goods were bought and sold as insole sheets. Rolling for convenience did not convert sheets into films or sheetings so as to deny the exemption.

Conclusion: The goods retained their identity as sheets, and the assessee was entitled to the benefit of the exemption notification.

Ratio Decidendi: Goods do not lose their statutory description merely because they are rolled for loading or transportation, unless the Revenue proves that their commercial identity is otherwise.

---