Tax exemption for bakery products turns on bakery turnover, not the dealer's other business, absent express restriction.

A tax exemption notification for bakery products was construed by reference to the turnover of bakery products, not the dealer's overall business. Because the notification barred exemption only where the total turnover in the relevant year exceeded the prescribed limit, and it did not expressly require exclusive engagement in bakery trade, the dealer's dealings in other commodities did not defeat the exemption. The court held that exemption remained available where the bakery-product turnover was below the threshold, and that such a restriction cannot be implied absent clear wording in the notification.

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Issues: Whether exemption from tax on bakery products was available where the dealer also dealt in other goods and the turnover of bakery products was below the prescribed limit of rupees two lakhs.

Analysis: The notification provided that exemption in respect of bakery products would not apply only where a dealer's total turnover in a year exceeded rupees two lakhs. On a plain reading, the controlling expression was the turnover arising from bakery products, and not the dealer's overall business in other commodities. The surrounding wording of the notification did not support the view that exemption was confined only to dealers exclusively engaged in bakery business, and the absence of any express indication of such a restriction in the notification was significant.

Conclusion: The dealer was entitled to exemption on the turnover of bakery products, as that turnover was below rupees two lakhs, even though the dealer also dealt in other articles.

Ratio Decidendi: Where a tax exemption notification is worded by reference to turnover in a specified class of goods, the exemption cannot be denied merely because the dealer carries on other business, unless the notification expressly imposes such a restriction.

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