Alternative seed exemption terms mean certified or truthfully labelled seeds each qualify for tax relief.

Exemption for sales or purchases of seeds used for agricultural purposes applied to seeds that were either certified or truthfully labelled, because the exemption order treated those descriptions as alternative categories rather than cumulative conditions. The Seeds Act scheme distinguished truthfully labelled seeds from certified seeds: truthful labelling was required for sale, while certification was only an optional process obtained on application. A later governmental clarification reinforced that certified seeds and truthfully labelled seeds were both covered, removing any ambiguity in the earlier order. The result was that the exemption extended to each qualifying category independently, and the denial of exemption was set aside.

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Issues: Whether the exemption granted to sales or purchases of certified and truthfully labelled seeds for agricultural purposes under the Government order covered seeds that were truthfully labelled though not certified, and whether the later governmental clarification entitled the assessee to exemption.

Analysis: The exemption order was issued under section 9(1) of the Andhra Pradesh General Sales Tax Act, 1957 and exempted sales or purchases of all varieties of certified and truthfully labelled seeds for agricultural purposes. The scheme of the Seeds Act, 1966 showed that truthfully labelled seeds and certified seeds were distinct concepts, since truthful labelling was required for sale while certification was only an optional facility obtainable on application to the certification agency. The subsequent memorandum clarified that certified seeds and/or truthfully labelled seeds were both exempt from tax, removing the earlier ambiguity and confirming that the two categories were not cumulative requirements.

Conclusion: The exemption applied to seeds that were either certified or truthfully labelled, and the assessee was entitled to the benefit of the exemption.

Final Conclusion: The revision succeeded and the denial of exemption was set aside, resulting in relief to the assessee.

Ratio Decidendi: Where an exemption notification uses distinct descriptions of goods in the alternative, and the statutory scheme shows that the conditions are separate rather than cumulative, the exemption must be applied to each qualifying category independently.

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