Agricultural implements exemption covers persian wheels used for bona fide farming; later clarification did not narrow the earlier entry.

Undefined exemption language for "agricultural implements" is construed by reference to the purpose of the exemption and the actual use of the goods. On that approach, persian wheels and their parts sold for bona fide agricultural purposes fall within item No. 35 of the Schedule of Exemptions and are exempt from sales tax. A later notification adding a specific entry for persian wheels did not exclude them from the earlier general entry; it was treated as clarificatory, though not retrospective, and relevant to the Government's understanding of the exemption.

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Issues: Whether persian wheels and their parts sold for bona fide agricultural purposes fall within the expression "agricultural implements" so as to be exempt under item No. 35 of the Schedule of Exemptions.

Analysis: The expression "agricultural implements" was not defined in the ordinance, so its scope had to be gathered from the purpose of the exemption and the actual use of the article. A later notification adding a specific entry for persian wheels did not mean that they were excluded from the earlier general exemption; it only clarified the position and removed doubt. The subsequent notification, issued under section 6(2) of the Ordinance, could not operate retrospectively, but it was still relevant in showing the Government's understanding of the item.

Conclusion: Persian wheels and their parts sold for bona fide agricultural purposes are agricultural implements within item No. 35 and are exempt from sales tax.

Ratio Decidendi: Where an exemption entry uses an undefined commercial or functional expression, its scope is determined by the purpose of the exemption and the actual use of the goods, and a later clarificatory entry does not exclude the goods from the earlier general exemption.

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