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    <title>2014 (8) TMI 444 - GAUHATI HIGH COURT</title>
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    <description>Entry tax on &quot;films of all kinds including X-ray films&quot; was construed strictly because it imposed a tax. As &quot;film&quot; was undefined, its meaning was taken from common parlance, not technical usage. The phrase &quot;including X-ray films&quot; was treated as qualifying the entry rather than broadly enlarging it, indicating that covered goods must share the relevant photosensitive character of X-ray films. On that reading, polyester film, metallised PET, metallised BOPP, aluminium foil film and poly film, lacking that character, were held outside entry No. 28. The clarificatory order and consequential show-cause and recovery notices were therefore unsustainable.</description>
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      <description>Entry tax on &quot;films of all kinds including X-ray films&quot; was construed strictly because it imposed a tax. As &quot;film&quot; was undefined, its meaning was taken from common parlance, not technical usage. The phrase &quot;including X-ray films&quot; was treated as qualifying the entry rather than broadly enlarging it, indicating that covered goods must share the relevant photosensitive character of X-ray films. On that reading, polyester film, metallised PET, metallised BOPP, aluminium foil film and poly film, lacking that character, were held outside entry No. 28. The clarificatory order and consequential show-cause and recovery notices were therefore unsustainable.</description>
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