Inclusive exemption for cattle fodder covered processed damaged wheat, so the tax demand could not be sustained.

An exemption notification using an inclusive definition of cattle fodder was construed in its general and trade sense, not as limited to the illustrative items named in the text. Damaged wheat that was processed and sold as cattle fodder was not shown to fall within any excluded commodity, so it was covered by the exemption. The tax demand could not be sustained.

---

---

Issues: Whether damaged wheat purchased and processed into cattle fodder falls within the expression "cattle fodder" in the exemption notification dated June 5, 1985.

Analysis: The notification used an inclusive definition of cattle fodder, mentioning certain items by way of illustration and excluding only specific commodities. The expression was held to cover cattle fodder in its general or trade sense, and not to be confined only to the illustrative items listed in the notification. Damaged wheat, once processed and sold as cattle fodder, was not shown to fall within any excluded category.

Conclusion: The processed damaged wheat was covered by the exemption as cattle fodder, and the tax demand could not be sustained.

---