Cattle feed exemption construed narrowly; deoiled rice bran cake remained taxable and writ review of assessment was declined.

Section 15 of the Haryana General Sales Tax Act, 1973, and Schedule B were construed as exempting only cattle feed as a composite mixture of specified ingredients, not each constituent item separately. Deoiled rice bran cake was validly brought within the taxable entry by the notification dated 29 March 1996, so the notification was not ultra vires. The court also declined to examine the assessment order in writ proceedings because the statute provided an appellate remedy and the challenge could not be tested without full facts.

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Issues: Whether the notification dated 29 March 1996 levying sales tax at 4% on deoiled rice bran cake was ultra vires section 15 of the Haryana General Sales Tax Act, 1973, and whether the assessment order could be assailed in writ proceedings.

Analysis: Section 15 and Schedule B exempted only cattle feed as a composite mixture of the specified ingredients; the exempted entry did not extend to each constituent item in isolation. The impugned notification separately brought deoiled rice bran cake within the taxable entry and there was no inconsistency between the taxing entry and the exemption entry. The challenge to the assessment order was not examined on merits because the statute provided an appellate remedy and the court was not prepared to enter into its validity in the absence of full facts.

Conclusion: The notification was not ultra vires section 15 of the Haryana General Sales Tax Act, 1973, and the writ challenge to the assessment order was not entertained.

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