Undefined customs terms are read broadly: beaded tape for zipper manufacture qualified as zip tape under the notification.

An undefined commercial expression in a customs notification is construed in its broad, ordinary sense unless the notification itself shows a narrower intention. On that approach, beaded tape imported for use in zipper manufacture was treated as "zip tape" within S. No. 2 of Notification No. 190/90, because the record did not show that the term was limited only to tape already fitted with teeth. The contrary classification under S. No. 4 was rejected, and the revenue's appeal succeeded, with the importer denied the lower classification benefit.

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Issues: Whether beaded tape imported for use in zipper manufacture fell within S. No. 2 of Notification No. 190/90 as "zip tape", or within S. No. 4 so as to entitle the importer to the benefit claimed.

Analysis: The entry "zip tape" was not defined in the notification. The imported goods were tape intended for use in zip fasteners, and the record did not establish that the expression was confined only to tape already fitted with teeth. In the absence of a restrictive definition, the expression was treated as a broad and comprehensive description covering both tape fitted with teeth and tape imported for that purpose.

Conclusion: The goods fell within S. No. 2 of the notification, not S. No. 4, and the revenue's appeal succeeded.

Final Conclusion: The importer was held not entitled to the lower authority's classification benefit, and the revenue obtained the relief sought by setting aside the order under challenge.

Ratio Decidendi: Where a notification uses an undefined commercial expression, it is construed in its comprehensive sense unless the text of the notification shows a narrower intended meaning.

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