Agricultural implement exemption narrowly construed: sugarcane crusher held outside sales tax relief because processing harvested cane is manufacturing.

A sugarcane crusher was not treated as an agricultural implement for exemption purposes because the agricultural process ends on harvesting, and extracting juice or preparing gur from harvested cane is manufacturing rather than agriculture. The Court construed the notification's inclusive wording in context and limited the general words to implements of the same kind as those specifically mentioned. The crusher therefore fell outside the exemption and remained liable to sales tax.

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Issues: Whether a sugarcane crusher (kohlu) is an agricultural implement within the meaning of the exemption notification so as to be exempt from sales tax.

Analysis: The notification exempted agricultural implements and illustrated them by items ordinarily used for cultivation, sowing, harvesting, and other operations that foster the growth and preservation of agricultural produce. The Court held that the agricultural process ends when sugarcane is harvested and that preparation of gur or extraction of juice from harvested sugarcane is a manufacturing activity, not a continuation of agriculture. The inclusive language of the notification was construed in its setting, and the general words were limited to implements of the same kind as those specified.

Conclusion: A sugarcane crusher does not fall within the expression agricultural implements and is not exempt from sales tax.

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