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Issues: Whether yarn manufactured by twisting two single yarns and then twisting in another single yarn again is covered by the expression "double or multifold yarn" in Notification No. 53/91-C.E., so as to qualify for exemption.
Analysis: The Central Excise Tariff did not separately classify the product as double fold, multifold or cabled yarn, and the dispute was only about the scope of the exemption notification. HSN Explanatory Notes were not treated as decisive for construing the notification because exemption notifications are to be interpreted on the basis of the description used in the notification and the domestic trade understanding. The trade notice from the Bombay Collectorate supported the view that cabled yarn was treated as multiple folded or cabled yarn and had been extended the benefit of the earlier notification in the same terms.
Conclusion: The yarn manufactured by the appellant was held to fall within the expression "double or multifold yarn" in Notification No. 53/91-C.E., and the exemption could not be denied. The appeals were allowed with consequential relief.
Ratio Decidendi: An exemption notification covering "double or multifold yarn" must be construed according to its own wording and domestic trade usage, and not by importing a restrictive distinction from HSN Explanatory Notes where the tariff itself does not make that distinction.