Ordinary commercial meaning of "enamelware" excludes tailor-made glasslined machinery, defeating exemption under excise notifications.

Tailor-made glasslined equipment such as autoclaves, distilling units, crystallising units, pressure filters and evaporating pans were held not to be "enamelware" for exemption purposes because the term, though undefined in the tariff and notifications, had to be read in its ordinary commercial sense. Glasslining could amount to enamelling, but that did not make large special-purpose machinery or customer-specific equipment "ware" in the trade sense of ready-made saleable articles. Trade notices on ordinary enamel articles could not be extended to such equipment, and a liberal reading of the exemption could not displace the plain meaning of the expression used. The exemption claim therefore failed.

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Issues: Whether tailor-made glasslined equipment such as autoclaves, distilling units, crystallising units, pressure filters and evaporating pans fell within the description of "enamelware" so as to qualify for exemption under the relevant excise notifications.

Analysis: The term "enamelware" was not defined in the tariff or the notifications, so its meaning had to be gathered from dictionaries, text books and trade understanding. Glasslining may amount to enamelling, but that did not make every glasslined article "enamelware". The expression "ware" in its ordinary commercial sense referred to readymade saleable articles ordinarily sold across the counter, not to huge special-purpose machinery and equipment manufactured to customer specifications. The trade notices and tariff advices relied upon related to ordinary enamel articles such as sign boards and photo trays and could not be extended to the disputed equipment. A liberal construction of an exemption notification could not override the plain meaning of the expression used.

Conclusion: The disputed goods were not enamelware and were not entitled to exemption. The appeal succeeded and the assessee's claim for exemption failed.

Ratio Decidendi: Where an exemption notification uses the expression "enamelware" without definition, the term must be understood in its ordinary commercial sense as referring to readymade saleable articles, and not to large tailor-made glasslined machinery or equipment.

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