Exemption notifications are read by ordinary meaning: a chaff-cutter is not a mower and does not qualify for sales tax relief.

An exemption entry in a sales tax notification must be confined to the ordinary meaning of the specified article. Applying that approach, the term "mower" refers to a machine used for cutting standing grass, hay or similar growth on the earth, not to an implement that chops already detached fodder. A chaff-cutter or kutti-ki-machine is functionally different from a mower and does not fall within the exemption notification, so it is not exempt from sales tax.

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Issues: Whether a chaff-cutter or kutti-ki-machine falls within the word "mower" in the exemption notification issued under Schedule I to the Madhya Pradesh General Sales Tax Act, 1958, so as to be exempt from sales tax.

Analysis: The relevant statutory scheme exempted only those agricultural implements specified by notification. The expression "mower" had to be understood in its ordinary and accepted sense in the context of the notification. Reading the notification as a whole, the item referred to a machine for cutting standing grass, hay or similar growth on the earth, not to an implement used after stalks, stems or fodder had already been cut and detached. A chaff-cutter or kutti-ki-machine chops fodder into pieces after removal from the earth and is therefore functionally different from a mower. The wider dictionary meanings relied upon did not justify extending the exemption beyond the natural meaning of the word used.

Conclusion: The chaff-cutter or kutti-ki-machine does not fall within the expression "mower" in the notification and is not exempt from sales tax. The finding is against the assessee and in favour of the Revenue.

Ratio Decidendi: An exemption entry in a sales tax notification must be confined to the ordinary meaning of the specified article, and a machine used to cut already detached fodder is not a mower for purposes of exemption.

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