Agricultural implements exemption: hand tools like pickaxe, shovel and crow-bar retained tax-free status despite other possible uses.

Pickaxe, shovel and crow-bar were treated as agricultural implements worked by hand within the scope of Notification S.R.O. No. 342 of 1963, because they are ordinarily used in agricultural operations and in making land fit for cultivation. Their possible use for road work or other non-agricultural purposes did not change their essential character. The later 1987 explanatory amendment was held inapplicable to the relevant assessment year, so the articles remained exempt from sales tax.

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Issues: Whether pickaxe, shovel and crow-bar are agricultural implements worked by hand and therefore exempt from sales tax under Notification S.R.O. No. 342 of 1963.

Analysis: The relevant notification as it stood for the assessment year concerned exempted agricultural implements worked by hand. The later explanatory amendment of 1987 was held to have no application to the assessment year 1984-85. Applying the principle that an agricultural implement is one used in agriculture and in making the land fit for cultivation, and that articles used after the agricultural process ends are not excluded merely because they may also have other uses, the Court held that pickaxe, shovel and crow-bar are generally used for agricultural operations. Their possible use for road work or other purposes did not alter their character as agricultural implements.

Conclusion: Pickaxe, shovel and crow-bar are agricultural implements within the meaning of Notification S.R.O. No. 342 of 1963 and are entitled to exemption from sales tax.

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