Strict construction of tax exemptions excludes spare parts from the term agricultural implements under the sales tax schedule.

Spare parts of agricultural implements were held not to fall within the expression "agricultural implements" in item No. 13 of Schedule I of the Bengal Finance (Sales Tax) Act, 1941. The term was given its ordinary meaning as apparatus or instruments used in agriculture, and spare parts were treated as replaceable components that do not, by themselves, answer that description. The exemption entry was construed strictly, so goods are exempt only when plainly covered by the language used. The later amendment expressly referring to spare parts, accessories and component parts for tractors and power tillers confirmed that the original entry did not include spare parts.

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Issues: Whether spare parts of agricultural implements are covered by the expression "agricultural implements" in item No. 13 of Schedule I of the Bengal Finance (Sales Tax) Act, 1941, so as to qualify for tax exemption.

Analysis: The expression "agricultural implements" was not defined in the Act and was construed according to its ordinary meaning as apparatus or instruments employed in agriculture. Spare parts are replaceable parts used in a machine and do not, by themselves, answer to the description of agricultural implements. The exemption under section 6 read with Schedule I was confined to the goods specifically enumerated, and spare parts were not included. The later amendment expressly referring to spare parts, accessories and component parts in relation to tractors and power tillers showed that, absent such express language, spare parts could not be treated as covered by the original exemption entry.

Conclusion: Spare parts of agricultural implements are not agricultural implements within item No. 13 of Schedule I and are not exempt from tax under the Act.

Ratio Decidendi: An exemption entry in a taxing statute must be strictly construed, and goods are exempt only if they are expressly or plainly covered by the language of the entry.

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