Broad construction of vegetable oil exemption covers refining industry; sales tax relief applies to raw material sales.

The expression "vanaspati industry (vegetable oil)" in the relevant exemption notification was construed broadly in its statutory context to include an industry refining crude vegetable oil, not merely vanaspati ghee manufacture. Because the notification used wide language and the legislative scheme showed that narrower coverage was stated expressly where intended, vegetable oil supplied as raw material to the refining industry fell within Item No. 23. Sales tax was therefore not payable on such sales, and the assessment and demand based on denial of the exemption could not stand.

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Issues: Whether the expression "vanaspati industry (vegetable oil)" in Item No. 23 of the Schedule to Notification No. 75/7 S. R. 55(51) dated 24.11.1953 included an industry engaged in refining crude vegetable oil, so as to exempt sales of vegetable oil used as raw material in that industry from sales tax.

Analysis: The charging provision under the Madhya Bharat Sales Tax Act, 1950 used the expression "all types of vegetable oils" and expressly excluded hydrogenated oils, showing that the expression "vegetable oil" was intended to bear a wide meaning unless restricted by clear words. The scheme of the notifications also showed that where the Government intended to confine the scope of vegetable oil, it used qualifying words such as "hydrogenated". Read in that context, the phrase "vanaspati industry (vegetable oil)" was not confined to vanaspati ghee alone. The words were understood to denote an industry in which vegetable oil was the chief raw material, and an industry refining crude vegetable oil fell within that description.

Conclusion: The sale of vegetable oil to the refining industry was covered by the exemption and was not liable to sales tax under Item No. 23.

Final Conclusion: The assessment and demand founded on the denial of exemption could not be sustained, and the petitioner was entitled to relief.

Ratio Decidendi: An exemption notification using broad words for vegetable oil must be construed according to their natural and wide meaning in the statutory context, and an industry refining crude vegetable oil may fall within a description covering vanaspati industry where the notification evinces an intent to exempt vegetable oils used for industrial purposes.

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