Ordinary commercial meaning governs tax exemptions, and rice bran is not included within husk absent clear wording.

Exemption notifications are construed in their ordinary commercial and dictionary sense, and rice bran was treated as distinct from husk because it arises during polishing of the grain rather than from the husk itself. The earlier notification separately referred to bran in addition to husk, which indicated that bran was not included within the broader expression. The later withdrawal of the separate reference to bran confirmed that the exemption was not intended to extend to rice bran. On that basis, rice bran did not fall within the exempted category of husk and the assessment challenge failed.

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Issues: Whether rice bran fell within the expression "husk of all grains, cereals, pulses and rice" in the exemption notification dated 1 April 1982 and was therefore exempt from sales tax.

Analysis: The expression "husk" was construed in its ordinary commercial and dictionary sense. Rice bran was held to be distinct from husk, since bran is obtained during polishing of the grain and is not a product of stalk, leaves, or husk. The earlier notification of 7 April 1967 separately mentioned "bran" in addition to "husk", showing that bran was not treated as husk. The withdrawal of the separate exemption for bran in the later notification indicated that the later notification did not intend to extend exemption to rice bran.

Conclusion: Rice bran was not exempt under the notification and the challenge to the assessment order failed.

Final Conclusion: The writ petition was rejected because the impugned orders correctly held that rice bran did not fall within the exempted category of husk.

Ratio Decidendi: For exemption purposes, tax notifications must be read according to the ordinary commercial meaning of the goods described, and a commodity separately identified in an earlier notification is not treated as included within a broader exempted category unless the notification clearly so provides.

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