Ordinary meaning of "pottery" limits sales tax exemption, so earthen tiles are excluded from the pottery industry benefit.

An exemption for the cottage pottery industry under the relevant sales tax notifications was construed by applying the ordinary meaning of "pottery". The Court referred to standard dictionary usage and held that earthenware is distinct from bricks and tiles; on that basis, earthen tiles could not be treated as pottery. The broader interpretation adopted by the Tribunal was therefore unsustainable. The exemption did not extend to the manufacture of earthen tiles, and the Tribunal's order was set aside to that extent.

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Issues: Whether earthen tiles fall within the expression "pottery" for the purpose of exemption under the relevant sales tax notifications.

Analysis: The dispute concerned the scope of the exemption for "cottage pottery industry" under the notifications issued under the U.P. Sales Tax Act. The Court examined the ordinary meaning of "pottery" and noted that standard dictionary usage distinguished earthenware from brick and tile. On that meaning, earthen tiles could not be treated as pottery. The Tribunal's broader view was therefore unsustainable.

Conclusion: Earthen tiles do not fall within the category of "pottery". The question was answered in favour of the revisionist and against the assessee.

Final Conclusion: The exemption for pottery industries did not extend to manufacture of earthen tiles, and the Tribunal's order was set aside to that extent.

Ratio Decidendi: An exemption expression must be construed according to its ordinary meaning, and earthen tiles are not included within "pottery".

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