Exemption for betel nuts under the sales tax schedule applies even when sold separately or by grocers.

Betel nuts remained within item No. 52 of the Schedule of Exemptions under the Pepsu General Sales Tax Ordinance, 2006 because the entry did not expressly require joint sale with pan or betel leaves, nor did it limit the exemption to any particular class of dealer. The text of the exemption could not be narrowed by implication merely because pan and betel nuts were mentioned together. On that construction, betel nuts were exempt from sales tax whether sold with pan or separately, and whether sold by panwalas or grocers.

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Issues: Whether betel nuts covered by item No. 52 of the Schedule of Exemptions under the Pepsu General Sales Tax Ordinance, 2006 remain exempt from sales tax when sold separately from pan or betel leaves, irrespective of whether they are sold by panwalas or by grocers.

Analysis: The exemption entry mentioned pan and betel nuts together, but it contained no express restriction that the exemption would apply only when both articles were sold together or only through a particular class of dealer. In the absence of such limiting words, the entry could not be read as imposing a condition not found in its text. The mere association of the two articles in one entry did not justify narrowing the exemption to joint sales.

Conclusion: Betel nuts were held to be exempt from sales tax whether sold with pan or separately, and whether sold by panwalas or by grocers.

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