Rice bran as cattle feed remains exempt where a rate notification cannot override a specific statutory exemption.

Rice bran was treated as cattle feed because its primary use and accepted commercial understanding placed it within the Schedule exemption under the Rajasthan Sales Tax Act, 1954, so it remained exempt from tax. The exemption under section 4(1) operated independently of the rate-fixing power under section 5, and a notification prescribing tax rates could not override a specific statutory exemption. The stated result was that the revision succeeded and the contrary orders of the subordinate authorities were set aside.

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Issues: Whether rice bran is cattle feed and therefore exempt under the exemption entry in the Schedule to the Rajasthan Sales Tax Act, 1954; and whether a notification issued under the rate-fixing provision can override that exemption.

Analysis: Rice bran was held to be cattle feed on the basis of its primary use and accepted commercial understanding. The exemption under section 4(1) operates independently of the rate notification issued under section 5. The fields of operation of exemption and rate provisions are distinct, and a notification prescribing tax rate cannot nullify a specific exemption granted by the Schedule.

Conclusion: Rice bran was exempt from tax as cattle feed, and the notification under section 5 did not override the exemption.

Final Conclusion: The revision succeeded, and the contrary orders of the subordinate authorities were set aside.

Ratio Decidendi: Goods falling within a specific exemption entry in the Schedule remain exempt, and a notification fixing tax rates under a separate charging or rate provision cannot override that statutory exemption.

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