1905 9090 by several rulings worldwide, there cannot be two interpretations while interpreting the products under HSN code. 25. Learned counsel for the petitioner has placed reliance on judgment of Kayani & Co. v. Commissioner of Sales Tax, [AIR 1953 AP 252], where the High court determined, whether double roti, shirmal, parata and chapati etc can be called bread. Hon’ble High Court held that the intention of the legislature was to include all kinds of bread which are consumed by the citizens of India, whether prepared in different ways or called by different names and therefore, there is no justification limiting the scope of the term bread to double roti, which is loaf or bread in European country. Learned counsel for the petitioner has also submitted that the advance ruling appellate authority has erred in applying Rule 3(c) of General Rule of Interpretation to hold that no heading/sub - heading covers the description of impugned products. The impugned products being Indian flat breads are covered under breads specified in heading 1905. Explanatory notes to heading 1905 also gives description of products covered thereunder as impugned products. It is also submitted that Rule 3(c) of the General Rules of Interpretation is not applicable since Heading 2106 comes later. Therefore, the impugned products cannot be said to be covered under Heading 2106. Rule 3(c) can be applied only where there are two equally meritorious
