Tax exemption for seeds turns on disjunctive eligibility, not cumulative conditions, under the clarified notification.

A tax exemption notification for certified and truthfully labelled seeds had to be read in the alternative, because the later clarification used the phrase "certified seeds and/or truthfully labelled seeds" and showed that the two categories were not cumulative. The Tribunal and High Court erred by requiring both certification and truthful labelling to coexist before exemption could apply. The correct approach was to test the assessee's eligibility against the disjunctive standard, including whether the seeds were truthfully labelled on the evidence produced. The matter was therefore remitted for reconsideration on that factual issue.

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Issues: Whether exemption under the sales tax notification applied to certified seeds and/or truthfully labelled seeds as alternatives, and whether the authorities had erred in insisting that both conditions must co-exist.

Analysis: The exemption order granted relief for sales or purchases of certified and truthfully labelled seeds for agricultural purposes, and the later clarification expressly stated that "certified seeds and/or truthfully labelled seeds" were exempt, showing that the two categories were alternatives and not cumulative requirements. The Tribunal and the High Court proceeded on the mistaken basis that both conditions had to be satisfied together. The factual question whether the assessee's seeds were truthfully labelled had not been properly examined in light of the clarification, and the assessee was required to produce evidence only on that issue.

Conclusion: The insistence that both certification and truthful labelling must co-exist was incorrect. The appeal was allowed and the matter was sent back for reconsideration on the factual aspect of truthful labelling.

Ratio Decidendi: Where a tax exemption notification is clarified by the Government to cover two categories in the alternative, the exemption cannot be denied by treating both conditions as cumulative; the factual eligibility must then be tested against the correct disjunctive standard.

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