Ordinary meaning of "livestock" includes one-day-old chicks, preserving sales tax exemption despite a later clarificatory notification.

In construing a fiscal exemption, the term "livestock" was given its ordinary popular meaning, and one-day-old chicks were treated as included within that expression; the exemption therefore applied to them under the relevant Government Order issued under the Andhra Pradesh General Sales Tax Act. The later specific notification exempting one-day-old chicks did not imply that no earlier exemption existed, because such later instruments may merely clarify the position or remove doubt. On that construction, the assessee was entitled to the exemption for the relevant earlier period.

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Issues: Whether one-day-old chicks fall within the expression "livestock" so as to qualify for exemption from sales tax under the relevant Government Order and the statutory power exercised under the Andhra Pradesh General Sales Tax Act, and whether the later specific exemption issued in 1992 implied that no exemption existed earlier.

Analysis: The exemption granted by G.O. Ms. No. 130, Revenue (CT-II) was issued in exercise of the power under section 9(1) of the Andhra Pradesh General Sales Tax Act, 1957. The decisive question was the scope of the word "livestock". The Court treated the observations in Royal Hatcheries as supporting the view that, in ordinary and popular understanding, chicks are included in livestock, and relied on dictionary meanings, published materials, and comparative authorities showing that livestock is commonly understood broadly to include poultry. The Court also held that the later notification specifically exempting one-day-old chicks did not necessarily mean that they were not already covered, because such later exemptions may be issued by way of abundant caution to remove doubt.

Conclusion: One-day-old chicks were held to fall within "livestock" for the purpose of the exemption, and the assessee was entitled to the benefit for the relevant period prior to the later notification.

Ratio Decidendi: In construing a fiscal exemption, a broadly used term such as "livestock" is to be understood in its ordinary popular sense unless the statute or notification restricts it, and a later clarificatory exemption does not by itself negate an earlier coverage already available on that construction.

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