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Issues: Whether the product described as a sprayer was classifiable as a hand pump and thus eligible for exemption under Notification No. 234/82.
Analysis: The product consisted of a pump and tank used for spraying insecticides and performed two functions, namely lifting the liquid and spraying it under pressure. As no definition of hand pump was available in the tariff, the test of commercial parlance applied. The material on tariff headings and HSN showed a clear distinction between pumps and appliances for spraying liquids, and the product was understood in trade and by the common man as a sprayer, not as a hand pump. Since sprayers and hand pumps are distinct commodities and are not treated as synonymous in trade or taxation classification, the exemption available to hand pumps could not be extended to the goods in question.
Conclusion: The product was not a hand pump and was not entitled to exemption under Notification No. 234/82; the appeal succeeded in favour of the Revenue.
Ratio Decidendi: Where a tariff entry does not define a product, classification must follow its commercial parlance meaning, and an exemption meant for one distinct commodity cannot be extended to another merely because the two operate on similar physical principles.