Broad reading of "automobiles" upheld exemption for steel seats used in tractors and earth-moving equipment.

Steel seats designed for use in automobiles remained eligible for exemption under the central excise notifications even though they were also usable in tractors and earth-moving equipment. The term "automobiles" was construed in the context of the notification as a whole, not by importing a narrower definition from the Automobile Cess Rules. Applying noscitur a sociis and the object of the exemption, the expression was given a broader meaning covering self-propelled conveyances suitable for road use, so the dual use of the seats did not alter their exempt character.

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Issues: Whether steel seats designed for use in automobiles, when capable of being used in tractors and earth-moving equipment, remained eligible for exemption under the relevant central excise notifications.

Analysis: The notifications exempted steel seats and chairs designed for use in automobiles, railway carriages and aircrafts. The expression "automobiles" was construed in the setting of the notifications as a whole, and not by importing a restrictive definition from the Automobile Cess Rules. The surrounding words indicated a broad class of self-propelled conveyances, and the principle of noscitur a sociis, read with the object and purpose of the exemption, supported a wider meaning. Tractors and dumpers were treated as motor vehicles suitable for road use, and the fact that the seats were also usable in earth-moving equipment did not destroy the character of the goods as seats designed for use in automobiles.

Conclusion: The steel seats were eligible for exemption under the notifications, even though they were also used in tractors and earth-moving equipment.

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