Unqualified "steel" in an exemption notification includes stainless steel tubes, pipes and blanks unless expressly excluded.

An exemption notification using the unqualified term "steel" was construed to include stainless steel tubes and pipes, as well as blanks therefor. The surrounding entries showed that when stainless steel was intended to be excluded, the notification said so expressly, and that contrast supported a broad reading of the word "steel". The challenge to the exemption interpretation therefore failed, and stainless steel products were treated as covered by the entry.

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Issues: Whether the expression "steel" in Serial No. 03 of the Table annexed to Notification No. 202/88-C.E. included tubes and pipes and blanks therefor of stainless steel.

Analysis: The notification used the expression "steel" without qualification. The surrounding exemption entries showed that where stainless steel was intended to be excluded, the notification said so expressly. The contrast with other entries in the same table supported the view that the unqualified term "steel" was wide enough to cover stainless steel products.

Conclusion: The expression "steel" in the notification included stainless steel tubes and pipes and blanks therefor, and the Revenue's challenge failed.

Ratio Decidendi: Where an exemption notification uses an unqualified expression for a commodity, stainless steel is included within "steel" unless the notification expressly excludes it.

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