Natural meaning in tax entries excludes dry cell batteries from last-sale levy under the Karnataka sales schedule.

Dry cell and dry cell batteries are excluded from Entry 3 of the Eighth Schedule to section 5(3-C) of the Karnataka Sales Tax Act, because the entry's natural wording excludes them separately after excluding pumpsets. Applying the ordinary rule of construction to a taxing entry, the exclusion cannot be confined only to pumpsets with electric motors of not more than 10 H.P. The correct reading is that dry cell and dry cell batteries do not fall within the levy at the last sale point, and the revisional authority's contrary interpretation was erroneous.

---

---

Issues: Whether dry cell and dry cell batteries fall within the exclusion in Entry 3 of the Eighth Schedule to section 5(3-C) of the Karnataka Sales Tax Act, 1957 so as to escape levy at the last sale point.

Analysis: Entry 3 referred to goods falling under item No. (iii) of serial No. 2 of Part E of the Second Schedule, namely electrical goods, instruments, apparatus and appliances, but it also used the words "but excluding pumpsets ... and dry cell and dry cell batteries". In construing a taxing schedule entry, the ordinary rule of construction applies and the words of the entry must be given their natural meaning. The use of the conjunction "and" after the exclusion of pumpsets indicated that dry cell and dry cell batteries were also separately excluded, and the exclusion could not be confined only to pumpsets with electric motors of not more than 10 H.P.

Conclusion: Dry cell and dry cell batteries are excluded from the levy under Entry 3, and the revisional authority's contrary view was wrong.

---