Plain-language reading of cattle feed exemption withdraws tax relief, with product classification remitted for chemical examination.

The notification dated 1 October 1994 was construed on its plain language, and cattle feed was treated as distinct from the exempt entry "cattle fodder"; no limiting word such as "balanced" was read into cattle feed. On that construction, the earlier exemption was withdrawn for cattle feed of all kinds and forms from that date, so it was not exempt from tax. However, the product's exact character could not be finally determined on the existing record, because its constituents and productivity effect required chemical examination and expert opinion. The matter was therefore remitted for fresh adjudication on whether the product was balanced cattle feed or otherwise.

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Issues: Whether the notification dated 1 October 1994 excluded all cattle feed from the entry "cattle fodder" and whether the dealer's cattle feed remained exempt from tax.

Analysis: The entry in the notification was read according to its plain language. The words "cattle feed" were treated as separate from "balanced poultry feed", and no additional qualification of "balanced" was read into the expression "cattle feed". On that construction, the exemption earlier available under "cattle fodder" stood withdrawn for cattle feed of all kinds and forms from 1 October 1994. The manufacture's classification as balanced cattle feed could not be finally affirmed only on the existing record, because the nature of the product required chemical examination and expert opinion on its constituents and productivity effect.

Conclusion: Cattle feed was held to be excluded from the exempt entry and not exempt from tax. The matter was remitted for chemical examination and fresh adjudication on whether the product was balanced cattle feed or otherwise.

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