Exemption entries must be read strictly: flower plants were held outside the sales tax exemption under the Bengal Finance Act.

Flower plants do not fall within item No. 7 of the Second Schedule to the Bengal Finance (Sales Tax) Act, 1941, because the exemption entry is construed according to its plain language. The word "plants" is read in context with the preceding reference to "vegetables, green or dried and vegetable seeds", and the qualifying language in the entry governs the whole provision. In exemption matters, the claimant bears the burden of showing that the goods clearly come within the exempting entry. On that construction, flower plants are not entitled to sales tax exemption.

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Issues: Whether flower plants fall within item No. 7 of the Second Schedule to the Bengal Finance (Sales Tax) Act, 1941 so as to be exempt from sales tax.

Analysis: The expression in item No. 7, read as a whole, was held to indicate that the word "plants" was controlled by the preceding words "vegetables, green or dried and vegetable seeds". The opening word "vegetables" supplied the key to the legislative intent, and the concluding expressions excluding medicinal preparations and sealed containers were taken to govern the entire entry. The language was found to be plain and not capable of the wider construction suggested on behalf of the assessee. In exemption cases, the burden lies on the claimant to bring the goods clearly within the exempting entry.

Conclusion: Flower plants are not exempted under item No. 7 of the Second Schedule to the Bengal Finance (Sales Tax) Act, 1941.

Ratio Decidendi: An exemption entry must be construed on its plain language, and where the wording shows that the qualifying expression governs the whole entry, goods not clearly covered by that language do not qualify for exemption.

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