Sales tax exemption for fish extends to processed fish products unless the notification expressly excludes them.

A sales tax exemption for "fish" was treated as broad enough to cover a processed fish product, because the notification excluded only canned fish and did not limit the term to fresh fish. The product, prepared by boiling, smoking, drying and curing, was commercially different from ordinary dried or salted fish, but it was not excluded merely because it had undergone processing or was in a dead or boiled form. The later clarification that dried and salted fish was exempt supported that wider construction. On that basis, the processed fish product remained within the exemption and was not liable to sales tax.

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Issues: Whether 'masi', a processed fish product, fell within the exemption for 'fish' under the notification, so as to escape sales tax.

Analysis: The notification exempted sales of fish, subject only to the express exclusion of canned fish. The product in question was prepared through boiling, smoking, drying and subsequent curing, and was commercially different from dried or salted fish. Although drying was one of the stages, the product was not merely dried fish. The expression 'fish' in the notification was not qualified so as to restrict it to fresh fish alone, and there was no basis to deny the exemption merely because the product had undergone processing or was in a dead or boiled form. The later clarification that dried and salted fish was exempt also supported the broad scope of the exemption.

Conclusion: 'Masi' was held to fall within the exemption for fish and was not liable to sales tax.

Ratio Decidendi: Where a sales tax exemption notification exempts fish without limiting the term to fresh fish and excludes only canned fish, a processed fish product remains exempt unless it is specifically taken out by the notification.

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