Pesticide exemption interpreted broadly to include insecticides, extending sales tax relief to mosquito repellant mats.

Mosquito repellant mats classified as insecticides were treated as falling within the exempted entry "pesticides" under the sales tax exemption notification. The analysis relied on the product's statutory registration and manufacturing licence, and on the ordinary meaning of "pest" and "pesticide," which was read broadly to include substances used to destroy or repel insects. Insecticides were therefore regarded as part of the wider genus of pesticides, and the exemption was not confined by any limiting words to exclude them. On that basis, the article was covered by the exemption from sales tax.

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Issues: Whether mosquito repellant mat, held to be an insecticide, falls within the exempted entry "pesticides" under the sales tax exemption notification.

Analysis: The article manufactured and sold by the assessee was accepted as an insecticide on the basis of the statutory registration and manufacturing licence. The exemption notification under section 6 of the Orissa Sales Tax Act, 1947 exempted "pesticides" without any limiting words. The ordinary meaning of "pest" and "pesticide" shows that a pesticide is a pest-killer and includes substances used to destroy or repel insects. On that basis, insecticides form part of the wider genus of pesticides. The Court declined to give the expression a restricted meaning and held that the exemption could not be confined so as to exclude insecticides.

Conclusion: Mosquito repellant mat, being an insecticide, is covered by the exempted entry "pesticides" and is entitled to exemption from sales tax.

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