Ordinary meaning of exemption entries governs rice bran was held outside "bhusi" and not protected by an earlier notification.

Rice bran did not fall within the ordinary meaning of "bhusi" in the sales tax exemption notification, because bhusa and bhusi refer to commodities derived from the stalk, leaves or husk of grains and rice bran was not such a commodity; it was therefore not exempt on that basis. The broader argument that rice bran was cattle fodder was outside the question referred and could not expand the reference. The earlier 1948 exemption notification was also held to have been superseded by the later notification of 31 March 1956, which confined exemption to the goods expressly listed. The reference was answered against the assessee.

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Issues: Whether rice bran fell within the term "bhusi" in the sales tax exemption notification, and whether the earlier exemption notification continued to exempt rice bran.

Analysis: The notification exempted cattle fodder and included specified items such as bhusi, chhilka, chokar, cotton seed, gowar and oil-cake. Rice bran was held not to be bhusi in common parlance, as bhusa and bhusi denote commodities obtained from stalk, leaves and husk of grains, whereas rice bran was not such a commodity. The wider contention that rice bran was cattle fodder as such was not the question referred for opinion and could not be used to enlarge the reference. The earlier 1948 exemption notification was also found to have been superseded by the later notification of 31 March 1956, which made only the goods in List II exempt from tax.

Conclusion: Rice bran was not exempt as bhusi under the notification, and the earlier exemption notification did not continue to protect it.

Final Conclusion: The reference was answered against the assessee and in favour of the department.

Ratio Decidendi: A commodity claimed to be exempt under an inclusive exemption entry must satisfy the ordinary meaning of the relevant exempted category, and a prior exemption notification stands displaced where a later notification restricts exemption to the goods expressly listed.

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