Agricultural implements exemption denied for gur-making equipment used in post-harvest manufacturing.

Cane crushers and boiling pans used to convert sugarcane into gur were treated as part of a manufacturing process, not agricultural operations, under the U.P. Sales Tax exemption for agricultural implements. The Court reasoned that agriculture ends when the crop is harvested and brought home, so later processing of produce does not fall within agriculture merely because the materials came from land. It also held that authorities on exemption from attachment of implements of husbandry did not govern the sales tax notification. The articles were therefore not agricultural implements and did not qualify for exemption from U.P. sales tax.

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Issues: Whether cane crushers and boiling pans used in the preparation of gur from sugarcane are agricultural implements within the meaning of the exemption notification issued under section 4 of the U.P. Sales Tax Act, 1948.

Analysis: The exemption applied only to agricultural implements. The decisive question was whether the articles in question were used in agriculture or in a later manufacturing process. The Court held that agriculture ends when sugarcane is harvested and brought home, and that the conversion of sugarcane into gur is a manufacturing activity, not an agricultural operation. The broader meaning of agriculture, including subsequent operations connected with cultivation, does not extend to activities performed after the agricultural process has ceased. The articles were therefore not implements of husbandry or agriculture merely because they were used on produce originally derived from land. The Court also distinguished authorities dealing with exemption from attachment of implements of husbandry, holding that they did not control the present sales tax exemption question.

Conclusion: Cane crushers and boiling pans are not agricultural implements for the purpose of the exemption notification and are not exempt from U.P. sales tax.

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