Strict meaning of "coal" excludes cinder under a sales tax exemption notification, denying the dealer tax relief.

Cinder does not fall within the exemption term "coal" under the U.P. Sales Tax Act notification because the word must be given its strict and ordinary meaning in English usage, not a loose dictionary sense. Coal is a mineral obtained from the earth, whereas cinder is the residue left after coal has been burnt and is therefore a product of combustion rather than coal itself. On that interpretation, sales tax exemption available to coal was held inapplicable to cinder.

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Issues: Whether cinder falls within the expression "coal" in the exemption notification issued under section 4 of the U. P. Sales Tax Act, so as to entitle the dealer to exemption from sales tax.

Analysis: The notification exempted coal, and the question was whether cinder could be treated as coal for that purpose. The Court held that dictionary usage was not ative and that the true test was the strict and ordinary meaning of the word as understood in the English language. Coal is a mineral obtained as such from the earth, whereas cinder is the residue left after coal has been burnt. Since cinder is produced only after coal has undergone combustion, it is not coal in its proper sense, even if it may resemble coal in some uses or be described loosely in a dictionary.

Conclusion: Cinder is not coal and, therefore, does not qualify for exemption under the notification.

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