Tax-free entry cannot be narrowed by notification; singhada, including dried singhada, stayed exempt from commercial tax.

Singhada was held to remain exempt from commercial tax in all forms, including dried singhada, because Entry 16 of Schedule I named it without qualification. Section 15 allowed exemption for listed goods and permitted only addition of goods or relaxation of conditions by notification; it did not authorise a notification to exclude or narrow a tax-free entry. The State's attempt to treat singhada as taxable kirana goods under Schedule II was therefore invalid, and the Commissioner's circular could not alter the statutory exemption. The statutory tax-free entry was required to be given full effect as written.

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Issues: Whether singhada, including dried singhada, was exempt from commercial tax under the tax-free entry in Schedule I of the Madhya Pradesh Vanijyik Kar Adhiniyam, 1994, and whether the State could tax it by notifying it as kirana goods in Schedule II.

Analysis: Section 15 of the Act exempts goods specified in Schedule I from tax and permits only addition of goods or relaxation of conditions by notification; it does not authorise exclusion of a listed tax-free item. Entry 16 of Schedule I specifically names singhada without any qualification, while the use of qualifying words elsewhere in the entry showed that the legislature knew how to restrict an item when it intended to do so. The legislative history also indicated that singhada had earlier been separately exempt and was later clubbed with other exempt goods without any indication that only fresh singhada was intended. A notification under Schedule II could not cut down the scope of the exemption, and the circular issued by the Commissioner could not alter the statutory effect of the tax-free entry.

Conclusion: Singhada in all forms, including dried singhada, remained exempt from commercial tax, and the notification treating it as taxable kirana goods was invalid.

Ratio Decidendi: A tax-free entry in the parent statute must be given its full statutory effect, and subordinate notification or administrative circular cannot restrict or override an exemption that is expressed without qualification.

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