Disjunctive taxing entry construed broadly: cotton seed oil qualifies as vegetable oil and falls within the sales tax schedule.

A taxing entry using the disjunctive phrase "vegetable and edible oils" was construed according to its plain meaning, so a commodity needed to satisfy either description, not both, to fall within the entry. As cotton seed oil was undisputedly vegetable oil, it was held to be covered by entry No. 7 of Part III of Schedule II to the M.P. General Sales Tax Act, 1958, and therefore taxable under that entry.

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Issues: Whether cotton seed oil fell within entry No. 7 of Part III of Schedule II to the M.P. General Sales Tax Act, 1958, which covered vegetable and edible oils.

Analysis: The expression in the relevant entry was construed on its plain meaning. The Court held that the entry was attracted if the commodity was either vegetable oil or edible oil, and not only if it satisfied both descriptions. Since it was not disputed that cotton seed oil was vegetable oil, the commodity was held to fall within the taxable entry.

Conclusion: Cotton seed oil was covered by entry No. 7 of Part III of Schedule II to the M.P. General Sales Tax Act, 1958, and the question was answered in the affirmative, against the department.

Ratio Decidendi: Where a taxing entry is framed in the disjunctive, a commodity answering either of the described classes is taxable under that entry.

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