Taxability of salt in sealed packets and containers turns on reading exemption and taxing notifications together.

Salt sold in sealed packets and containers was held taxable under the Orissa Sales Tax Act because the exemption and taxing notifications had to be read together. The qualifying word "sealed" was applied to both "packets" and "containers," so the exemption did not extend to packed salt sold outside that notified form. Liability depended on the charging provision, while exemption operated only within the limits expressly notified by the State Government. On that construction, salt sold in the relevant packed form remained taxable and the applicant's contrary interpretation was rejected.

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Issues: Whether salt sold in gunny bags and nylon bags was taxable under the Orissa Sales Tax Act, 1947, and whether the expression "sealed" governed both packets and containers in the exemption and taxing notifications.

Analysis: The liability of a registered dealer depends on the charging provision, while exemption from tax operates only to the extent notified by the State Government. The relevant notifications exempted salt except when sold in sealed packets and containers, and separately taxed salt when sold in sealed packets and containers. Reading the exemption and taxable entries together, the expression "sealed" was held to qualify both packets and containers. Salt sold in containers was therefore not excluded from tax merely because the containers were not sealed in the manner suggested by the applicant.

Conclusion: The sale of salt in the relevant packed form was taxable, and the applicant's contention was rejected.

Final Conclusion: The application for a reference was dismissed because the taxing view was upheld and no case was required to be stated.

Ratio Decidendi: Where exemption and taxing entries are framed in corresponding language, they must be read together to determine the scope of taxation, and the qualifying word in the notification governs the entire composite expression unless the context clearly indicates otherwise.

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