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Issues: Whether filter candles manufactured for use in water filters were entitled to exemption as "candles" under Notification No. 104/82-C.E. dated 28-2-1982.
Analysis: The expression "candles" in the exemption notification was examined in its ordinary trade sense. The goods in question were filter candles, distinct from wax candles, and there was no acceptable evidence that they were known in trade simply as candles. The reference in the Indian Standards note was read in the context of filter candles and did not establish a broader trade meaning. Past practice in other Collectorates was held irrelevant, and no ambiguity was found to invoke the benefit of doubt in favour of the assessee.
Conclusion: The filter candles were not covered by the exemption notification.
Final Conclusion: The exemption claim failed and the departmental order denying relief was sustained.
Ratio Decidendi: An exemption entry must be applied according to the ordinary trade understanding of the goods, and where the goods are not shown to be known by the exempted description, exemption cannot be extended on the basis of claimed ambiguity.