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Issues: Whether charcoal and firewood sold for use in Government hospitals were sold for "domestic use" within entry 29 of the Fifth Schedule to the Mysore Sales Tax Act so as to qualify for exemption under section 8(1) of the Act.
Analysis: The exemption depended on the true meaning of the expression "sold for domestic use". The restrictive view taken by the taxing authorities treated the word "domestic" as importing a requirement that the goods must be used in a house or home. The Court rejected that approach and held that the decisive factor is the character of the use to which the article is put, not the place where it is used. The expression covers use for ordinary household-type purposes such as cooking, boiling water, laundry, or similar services commonly associated with domestic life, even if the use occurs outside a house or home.
Conclusion: Charcoal and firewood supplied for use in the hospitals for such purposes were sold for domestic use and were exempt from tax under the relevant entry.
Ratio Decidendi: For an exemption entry using the expression "sold for domestic use", the governing test is the nature of the use and not the physical location of use; domestic use is not confined to use within a house or home.