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Issues: Whether the goods manufactured by the assessee, namely reflectors, exhaust silencers and sign boards made from steel sheets and fabricated to purchasers' specifications, were covered by the expression "enamelware" and entitled to exemption under Notification No. 76/86-C.E. dated 10-2-1986.
Analysis: The expression "enamelware" was not defined in the tariff or the notification, so its meaning had to be gathered from dictionary usage and common parlance. The material relied upon showed that "ware" denotes articles of merchandise or manufacture ordinarily sold as ready-made saleable goods. The products in question were industrial items made to specific orders and used in industry, which placed them outside the ordinary understanding of "enamelware". The earlier Tribunal decisions on similar goods were applied, and the ratio was treated as directly governing the present dispute.
Conclusion: The goods were not "enamelware" and were not eligible for exemption under Notification No. 76/86-C.E. dated 10-2-1986. The classification made by the Collector was sustained.
Final Conclusion: The exemption claim failed and the departmental classification and duty liability were upheld.
Ratio Decidendi: Where an expression in an exemption notification is undefined, it must be understood in its ordinary/common parlance sense, and industrial goods made to specific orders do not fall within a term denoting ready-made saleable ware.