Broad interpretation of "waste paper" supports sales tax exemption for kraft box, sweeping kraft and duplex waste.

An exemption entry using the unqualified expression "waste paper" was interpreted broadly to include kraft box waste, sweeping kraft and duplex waste, because the term was not defined narrowly and covered the ordinary commercial understanding of paper waste. The restrictive distinction drawn by the Tribunal was considered unwarranted. The later clarification in G.O. Ms. No. 540 dated 05.09.2002 was also referred to as consistent with that broader reading. On that basis, the goods were treated as eligible for exemption from sales tax under G.O. Ms. No. 130 dated 14.02.1989.

---

---

Issues: Whether the expression "waste paper" in G.O. Ms. No. 130 dated 14.02.1989 includes kraft box waste, sweeping kraft and duplex waste and, accordingly, entitles those goods to exemption from sales tax.

Analysis: The expression "waste paper" was not defined narrowly in the exemption order. The goods sold by the assessees were treated as falling within the broader category of waste paper, and the court also referred to the classification of such paper items in the First Schedule and the later clarification in G.O. Ms. No. 540 dated 05.09.2002. The Tribunal's restrictive distinction was held to be unwarranted.

Conclusion: The goods in question were held to be covered by "waste paper" and entitled to exemption from sales tax under G.O. Ms. No. 130 dated 14.02.1989, as clarified by G.O. Ms. No. 540 dated 05.09.2002.

Ratio Decidendi: Where an exemption notification uses an unqualified expression for waste paper, paper waste falling within that ordinary and broader commercial understanding is entitled to the exemption unless the notification expressly excludes it.

---