Exemption notification interpretation extends "insecticides" to mosquito repellents where commercial and technical usage supports the wider meaning.

Mosquito repellent coils were treated as falling within the expression "insecticides" in Notification No. 55/75-C.E. for exemption purposes. The interpretation was not confined to substances that kill insects in a narrow etymological sense; trade usage, technical reference works, and HSN explanatory notes supported a wider commercial meaning that includes repellents. Reliance on the Insecticides Act was not decisive for construing the excise exemption notification. On that basis, the exemption was admissible and the assessee succeeded.

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Issues: Whether mosquito repellent coils were covered by the expression "insecticides" in Notification No. 55/75-C.E. dated 1-3-1975 so as to qualify for exemption from central excise duty.

Analysis: The product did not kill mosquitoes, but only repelled them. The Court accepted that the term "insecticide" in the exemption notification was not confined to substances which destroy insects in the narrow, etymological sense. The evidence on record, including trade usage, reference works on pesticides and entomology, and the H.S.N. explanatory notes, showed that repellents are also treated as insecticides or pesticides in modern commercial and technical usage. The restrictive reliance on the Insecticides Act was not decisive for interpreting the excise exemption notification.

Conclusion: Mosquito repellent coils were held to be insecticides within the meaning of Notification No. 55/75-C.E. and the exemption was admissible, in favour of the assessee.

Ratio Decidendi: For interpreting an exemption notification, the term "insecticide" may extend beyond insect-killing substances to include insect repellents where the commercial, technical, and modern usage of the expression supports such a wider meaning.

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