Ordinary meaning controls sales tax exemptions: betel leaves are not "green vegetables" and no exemption applied.

Fiscal exemption entries must be construed in their ordinary, commercial and popular sense, having regard to the context of the notification. On that approach, betel leaves were held not to fall within "green vegetables" under the U.P. sales tax exemption notification, because they are ordinarily used as a masticatory after meals rather than as food eaten as vegetables. The later notification granting a specific prospective exemption for betel leaves did not change the meaning of the earlier entry; it only created a new exemption for the future. The exemption was therefore unavailable in respect of the earlier notification.

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Issues: Whether betel leaves fall within the expression "green vegetables" in the sales tax exemption notification issued under the U.P. Sales Tax Act.

Analysis: The expression "green vegetables" was construed in its ordinary and commonly understood sense, having regard to the setting of the exemption notification and the contrast with other separately listed items such as cereals, pulses, edible oils, tobacco leaves, and groundnuts. Betel leaves are not ordinarily treated as vegetables or as food eaten with principal meals; they are used as a masticatory after meals. The later notification exempting betel leaves prospectively did not alter the meaning of the earlier notification, but only granted a later specific exemption.

Conclusion: Betel leaves do not fall within the meaning of "green vegetables" in the 1948 notification, and the exemption was not available to the assessee.

Ratio Decidendi: A fiscal exemption entry must be construed according to the ordinary commercial and popular meaning of the words used in the notification, and an item used as a masticatory rather than as a food vegetable will not be treated as a "green vegetable" absent clear language to that effect.

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