Broad construction of "rice" covers atukulu and muramaralu, preventing a second tax incidence on the same commodity.

Atukulu and muramaralu were held to fall within the statutory expression "rice" in entry 66(b) of the Andhra Pradesh General Sales Tax Act. The Court reasoned that parching and puffing change only the form of the commodity, not its essential identity, and that the scheme did not create a separate taxable category for rice so processed. It also applied the settled rule of strict construction in favour of the assessee where a taxing entry is reasonably open to two meanings, particularly where a narrower view would create an unfair second incidence of tax on the same commodity. The levy was therefore not sustainable on the contrary interpretation.

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Issues: Whether atukulu (parched rice) and muramaralu (puffed rice) are rice within the meaning of entry 66(b) of Schedule I to the Andhra Pradesh General Sales Tax Act, 1957.

Analysis: The entry used the broad expression "rice", and the statutory scheme distinguished between paddy and rice while not creating a separate taxable category for rice merely heated, parched, or puffed into an edible form. The Court treated parching and puffing as processes that altered form but not essential identity. It also applied the settled rule that where a taxing entry is reasonably capable of two meanings, the construction favourable to the assessee should prevail, especially where a narrower reading would produce an apparently unfair double incidence of tax on the same commodity in different forms. The history of exemption and the absence of a specific separate entry for these products reinforced the wider interpretation of "rice".

Conclusion: Atukulu and muramaralu are rice within entry 66(b), and the levy could not be sustained on the contrary view.

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