Concessional sales tax entry cannot be extended to groundnut oil made from groundnut oil-cake; higher rate applies.

Groundnut oil extracted from groundnut oil-cake does not qualify for the concessional tax rate under entry 24(b) of the Andhra Pradesh General Sales Tax Act, 1957, because that concession applies only where the raw material is groundnut that has already suffered tax. The wording of the entry is limited to that specific material and cannot be expanded to cover oil produced from groundnut oil-cake, which is a different raw material. A fiscal concession must be construed strictly according to its express language, so the higher rate under entry 24(a) applies.

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Issues: Whether groundnut oil extracted from groundnut oil-cake qualifies for the reduced rate of tax under entry 24(b) of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957, or is taxable at the higher rate under entry 24(a).

Analysis: The reduced rate in entry 24(b) applies only where the raw material for extracting groundnut oil is groundnut that has suffered tax. The language of the entry does not extend the concession to oil extracted from groundnut oil-cake, which is a different raw material. A concessional fiscal entry cannot be enlarged beyond its clear wording merely because the raw material has suffered tax. The interpretation adopted by the Tribunal was inconsistent with the phraseology used by the Legislature.

Conclusion: Groundnut oil extracted from groundnut oil-cake is not eligible for the reduced rate under entry 24(b) and falls under entry 24(a).

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