Printing and Writing Paper exemption covers paper fit for printing, writing, or both under a broad notification reading

The phrase "Printing and Writing Paper" in the exemption notification was construed broadly, not as a requirement that paper possess both printing and writing qualities simultaneously. Reading the word "and" in a disjunctive sense, the Tribunal held that the benefit extends to paper suitable for printing only, writing only, or both uses. On that interpretation, the assessees were entitled to the exemption under the notification.

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Issues: Whether the expression "Printing and Writing Paper" in Serial No. 1 of Notification No. 24/84-C.E. dated 1-3-1984 covers only paper having both printing and writing qualities, or also includes printing paper, writing paper, and paper suitable for both uses.

Analysis: The expression in the exemption notification was examined in the light of an earlier Tribunal view on similar wording. The Tribunal held that the words "printing" and "writing" describe analogous forms of paper use and that there was no rational basis to confine the benefit only to paper having both qualities. The word "and" was read in a disjunctive sense, so that the notification would extend to paper fit for printing only, writing only, or both printing and writing.

Conclusion: The expression "Printing and Writing Paper" includes printing paper, writing paper, and paper having both qualities; the assessees were entitled to the exemption.

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