Hand-made bidis fall within the tobacco exemption, as tariff classification does not limit the sales tax notification.

Hand-made bidis fall within the sales tax exemption for "tobacco and all its products" because the notification adopts a broad statutory definition of tobacco, covering tobacco in any form, whether cured or uncured and whether manufactured or not. Read with the excise law definition of manufacture, which includes preparation of biris in relation to tobacco, hand-made bidis are treated as manufactured tobacco. The excise tariff classification for machine-made bidis does not narrow the scope of the exemption notification. On that basis, the text states that hand-made bidis are exempt from sales tax and the assessment taxing them was liable to be quashed.

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Issues: Whether hand-made bidis are covered by the exemption for "tobacco and all its products" under the sales tax notification, and whether the excise tariff classification relating to machine-made bidis restricts that exemption.

Analysis: The exemption notification initially exempted "tobacco and all its products" and, after amendment, adopted the meaning of "tobacco" as defined in section 2(c) of the Additional Duties of Excise (Goods of Special Importance) Act, 1957, which in turn refers to item 4 of the First Schedule to the Central Excises and Salt Act, 1944. That definition is broad and includes tobacco in any form, whether cured or uncured and whether manufactured or not. Read with section 2(f) of the Central Excises and Salt Act, 1944, which includes the preparation of biris within "manufacture" in relation to tobacco, hand-made bidis fall within manufactured tobacco. The rate classification in the tariff item for excise duty does not narrow the meaning of tobacco adopted by the sales tax exemption notification.

Conclusion: Hand-made bidis are exempt from sales tax under the notification, and the assessment taxing them was liable to be quashed.

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