Meter length under Rule 96ZI was confined to one roller only, rejecting the department's broader calculation method.

For Rule 96ZI, "meter length" in an embroidery machine with two rollers was to be reckoned by reference to one roller only, because the later amendment was treated as clarificatory of an originally undefined expression and consistent with the earlier departmental circular. The broader departmental method of counting both rollers was not accepted, so the assessee's method was upheld and the challenge failed.

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Issues: Whether, for the purpose of Rule 96ZI, the expression "meter length" in an embroidery machine having two rollers was to be reckoned by taking both rollers together or by taking only one roller.

Analysis: Rule 96ZI originally contained no definition of "meter length". The later amendment was treated as clarificatory and consistent with the earlier Board circular, which understood "meter length" to mean the length of one roller only, even where the machine had two rollers. The departmental view based on a broader reckoning was not accepted.

Conclusion: "Meter length" was to be computed with reference to one roller only, and the department's challenge failed.

Final Conclusion: The appeal was rejected and the assessee's method of reckoning meter length was upheld.

Ratio Decidendi: Where a delegated provision is amended only to clarify an originally undefined expression, the clarification may be applied to understand the provision consistently with the earlier departmental circular.

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