Tax classification of fish and prawn feed treated as covered by the feed entry, with ambiguity resolved for the assessee.

Fish and prawn feed was treated as falling within entry 80 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957, on the basis that the Tribunal's classification was supported by the record, including the certificate relied on below. The stated approach was that any doubt or ambiguity in a tax classification entry should be resolved in favour of the assessee. On that reasoning, fish/prawn feed was covered by the entry and the tax revision was dismissed.

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Issues: Whether fish/prawn feed is classifiable as poultry feed and cattle feed under entry 80 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957.

Analysis: The Tribunal's view treating fish/prawn feed as covered by entry 80 was supported by the material on record, including the certificate relied on below and the principle that where there is doubt or ambiguity in the classification entry, the matter should be resolved in favour of the assessee.

Conclusion: Fish/prawn feed was held to fall within entry 80, and the tax revision was dismissed.

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