Tariff classification of nylon filament turned on the ordinary meaning of yarn and the rule of doubt in fiscal statutes.

Nylon bristles and fishing lines, described in trade as nylon filament, were treated as not falling within the ordinary meaning of "yarn" for purposes of the erstwhile Central Excise Tariff. Because Tariff Item 18 did not define yarn with sufficient precision for the relevant period, and the product did not match the textile glossary meaning, the classification remained ambiguous. Applying the settled rule that fiscal ambiguity must be resolved in favour of the assessee, the lower authorities' classification was set aside and the product was treated as outside Tariff Item 18.

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Issues: Whether nylon bristles and fishing lines, commonly known as nylon filament, were classifiable under Tariff Item 18 of the erstwhile Central Excise Tariff.

Analysis: The product was shown on the evidence to be known in trade as nylon bristles and fishing lines and not as yarn. Tariff Item 18 did not define yarn with sufficient precision for the old tariff period, and the product did not conform to the ordinary meaning of yarn as reflected in the relevant textile glossary. In the absence of adequate descriptive detail and in view of the resulting ambiguity in classification, the rule applicable to fiscal statutes required that doubt be resolved in favour of the assessee.

Conclusion: The product was not held classifiable under Tariff Item 18 and the classification adopted by the lower authorities was set aside in favour of the assessee.

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