Ordinary meaning of "husk" brings wheat bran or chokar within the sales tax exemption under the relevant schedule entry.

The term "husk" in item 15 of Schedule B to section 6 of the Punjab General Sales Tax Act, 1948 was construed in its ordinary and commercial sense. Wheat bran or chokar was treated as the inner husk of wheat, separated after grinding, and as a marketable grain covering used for animal consumption. On that basis, it was held to fall within the exempt entry, consistent with earlier Division Bench decisions treating chokar and similar grain coverings as covered by the exemption. The result was that wheat bran or chokar was recognised as exempt from sales tax under the relevant schedule entry.

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Issues: Whether wheat bran or chokar is husk of wheat or gram and, if so, whether it falls within item 15 of Schedule B to section 6 of the Punjab General Sales Tax Act, 1948.

Analysis: The expression "husk" in item 15 was construed in its ordinary and commercial sense. The Court accepted the view that bran or chokar is the inner husk of wheat, separated after grinding, and that earlier Division Bench decisions had already treated chokar and similar grain coverings as falling within the exempt entry. The Court also noted that the legislature could not have intended to exclude such a marketable commodity used for animal consumption from the exemption, and respectfully agreed with the reasoning in the prior decisions.

Conclusion: Wheat bran or chokar is covered by item 15 of Schedule B to section 6 of the Punjab General Sales Tax Act, 1948, and is exempt from sales tax.

Final Conclusion: The reference was answered in the affirmative, confirming the exempt status of wheat bran or chokar under the relevant sales tax entry.

Ratio Decidendi: A term used in an exemption entry must be given its ordinary meaning, and wheat bran or chokar, being the inner husk of the grain, falls within "husk" for the purposes of the exemption.

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