Taxing notifications must follow specific schedule wording: polythene sheets, plastic waste, and turnover findings were not disturbed.

Taxing notifications must be read by their specific schedule entries, and reduced-rate or exemption coverage cannot be extended beyond the wording used. On that approach, polythene sheets were not treated as packing materials within the relevant notification, and polythene tubings were covered only from the later prospective date when expressly brought in. Plastic waste was recognised as a distinct taxable item from plastic itself under the schedule. The turnover finding was supported by reliable evidence and disclosed no question of law requiring interference in revision. The revision challenges were therefore rejected and the Tribunal's assessment and turnover findings were left undisturbed.

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Issues: (i) whether polythene sheets and polythene tubings were entitled to reduced tax rate as packing materials under the exemption notifications; (ii) whether plastic waste could be treated as plastic for the purpose of assessment; (iii) whether any interference was warranted with the Tribunal's finding on turnover.

Issue (i): whether polythene sheets and polythene tubings were entitled to reduced tax rate as packing materials under the exemption notifications.

Analysis: The reduced-rate notifications were construed by reference to their specific entries. The schedule distinguished between general packing materials and particular finished items such as polythene tins, bags and covers. The Court applied the common parlance approach to taxing entries and held that the wording of the notifications did not extend to polythene sheets as such. Polythene tubings were brought within the notification only later and from the stated prospective date, which showed that earlier periods were not covered.

Conclusion: The claim for reduced tax on polythene sheets and polythene tubings failed. The finding was in favour of the Revenue.

Issue (ii): whether plastic waste could be treated as plastic for the purpose of assessment.

Analysis: The Court accepted the distinction drawn in the schedule between plastic as a taxable commodity and plastic waste as a different item. The assessment entries treated plastic waste separately, and the Tribunal's classification was supported by the statutory scheme.

Conclusion: Plastic waste was not treated as the same taxable item as plastic. The finding was in favour of the Revenue.

Issue (iii): whether any interference was warranted with the Tribunal's finding on turnover.

Analysis: The Court found that the turnover determination rested on reliable evidence and did not disclose any question of law calling for interference in revision.

Conclusion: No interference was warranted with the turnover finding. The finding was in favour of the Revenue.

Final Conclusion: The revision challenges to the assessment and turnover findings were rejected, and the assessments as sustained by the Tribunal remained undisturbed.

Ratio Decidendi: In construing taxing notifications and entries, specific words in the schedule control the scope of exemption or reduced rate, and an item not expressly covered cannot be brought within the entry merely because it may be capable of a similar use; classification follows the statutory wording and common parlance understanding.

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