Tax exemption for green vegetables is confined to edible vegetables for human consumption; sugar-cane is excluded.

A tax exemption for "green vegetables other than potatoes" was construed in its statutory context and by common usage as covering edible vegetables ordinarily understood as food for human consumption, whether cooked or uncooked. Sugar-cane did not fall within that ordinary meaning and was therefore not covered by item 6 of Notification No. 9884-F.T. dated 28.08.1947. The result was that sugar-cane remained taxable and the issue was decided in favour of the Revenue and against the assessee.

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Issues: Whether sugar-cane falls within the expression "green vegetables other than potatoes" in item 6 of Notification No. 9884-F.T. dated 28.08.1947 and is therefore exempt from sales tax.

Analysis: The expression "green vegetables" was construed in the setting of the other exempted articles in the notification, all of which were ordinary articles of food fit for human consumption. On that contextual reading, and also having regard to common usage and dictionary meaning, the expression was held to refer to vegetables eaten by human beings either cooked or uncooked. Sugar-cane did not answer that description and was not treated as a green vegetable within the notification.

Conclusion: Sugar-cane is not a green vegetable within item 6 of Notification No. 9884-F.T. dated 28.08.1947 and is not exempt from taxation. The question was answered in favour of the Revenue and against the assessee.

Ratio Decidendi: A tax exemption for "green vegetables" must be construed in its statutory context and is confined to edible vegetables ordinarily understood as food for human consumption.

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