Incorporated tax exemption definitions do not extend to tobacco seed oil and cake outside the express statutory meaning.

Tobacco seed, tobacco seed oil and tobacco seed cake do not fall within the statutory exemption for "tobacco" under section 8 read with the Fourth Schedule of the Andhra Pradesh General Sales Tax Act. The Court treated the exemption as dependent on the incorporated excise-law definition of tobacco, which covers the plant's specified parts such as leaf, stalks and stems, but not seed. Because the seed itself is outside that definition, products obtained from crushing the seed also remain outside the exemption and are liable to sales tax. The decision applies the principle that an incorporated taxing definition cannot be enlarged beyond its express scope.

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Issues: Whether tobacco seed oil and tobacco seed cake are exempt from sales tax as "tobacco" under section 8 read with the Fourth Schedule of the Andhra Pradesh General Sales Tax Act.

Analysis: The exemption in section 8 applies only to goods specified in the Fourth Schedule, and item 7 adopts the meaning of "tobacco" as defined in the Additional Duties of Excise (Goods of Special Importance) Act, 1957, which in turn incorporates item 4 of the First Schedule to the Central Excises and Salt Act, 1944. That definition covers any form of tobacco and specifically includes the leaf, stalks and stems of the tobacco plant, while excluding any part of the plant while still attached to the earth. On that language, tobacco seed is not brought within the definition, and if the seed itself is outside the definition, the oil and oilcake obtained by crushing the seed cannot qualify as tobacco either. The earlier view treating tobacco seeds as tobacco was not accepted as binding on the present issue, and the interpretation of the inclusive words in the excise definition was confined to the parts expressly mentioned.

Conclusion: Tobacco seed, tobacco seed oil and tobacco seed cake are not exempt as "tobacco" under section 8 read with the Fourth Schedule of the Andhra Pradesh General Sales Tax Act.

Final Conclusion: The writ petitions were dismissed because the disputed goods were held liable to sales tax and outside the statutory exemption.

Ratio Decidendi: Where a taxing exemption adopts another statute's definition by incorporation, the exemption extends only to the goods clearly brought within that definition, and an inclusive definition cannot be enlarged beyond its express scope to cover analogous goods not specified therein.

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