Strict construction of exemption notification excludes cart wheels from "cart" for sales tax purposes.

The expression "cart" in entry B-16 of the agricultural implements notification did not extend to cart wheels for sales tax exemption. The notification separately referred to component parts in some entries, and that deliberate omission for carts indicated a confined exemption to the cart itself. The court also read the relevant part of the notification as directed to bullock-drawn agricultural implements and declined to enlarge the entry by implication. The claim for exemption therefore failed, and the reference was answered against the assessee and in favour of the Revenue.

---

---

Issues: Whether the expression "cart" in entry B-16 of the agricultural implements notification included cart wheels for the purpose of exemption from sales tax.

Analysis: The notification issued under the delegated power under the Haryana General Sales Tax Act, 1973 expressly named several agricultural implements and, in some entries, specifically included their component parts. The omission of any reference to the parts of a cart, when contrasted with entries where parts were expressly mentioned, showed a deliberate legislative choice to confine the exemption to the cart as such. The heading and contents of the relevant part of the notification also indicated that the exemption was intended for bullock-drawn agricultural implements, and the court declined to extend the entry by implication to cart wheels. The reasoning in the cited authorities did not support a broader construction on the facts of this case.

Conclusion: Cart wheels are not included within the expression "cart" in entry B-16, and the claim to exemption fails. The reference is answered against the assessee and in favour of the Revenue.

---