Pre-amendment cattle feed treated as cattle fodder, preserving exemption from trade tax for the relevant years.

For assessment years before the 10.10.1994 amendment, cattle feed sold as a concentrate and tonic for cattle fell within the ordinary scope of "cattle fodder" under the exemption entry, as already judicially construed. The later amendment excluding cattle feed operated prospectively and did not affect the pre-amendment period. On that basis, the assessee's cattle feed remained covered by the exemption from trade tax for the relevant years.

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Issues: Whether cattle feed manufactured and sold by the assessee was includable in the expression "cattle fodder" under entry No. 10 of the exemption notification for the assessment years prior to the amendment dated 10.10.1994.

Analysis: The assessment years in question were all prior to the amendment of 10.10.1994 by Notification No. TT-3401, when cattle feed was excluded from cattle fodder. For the pre-amendment period, the earlier decision of the Court had already held that Parag Pashu Aahar, being cattle feed sold as a concentrate and tonic for cattle, fell within the expression "cattle fodder" in entry No. 10 and was therefore exempt from trade tax. The same reasoning applied to the assessee's cattle feed for the relevant assessment years.

Conclusion: Cattle feed was held to be included in "cattle fodder" for the assessment years involved, and the assessee was entitled to exemption from trade tax for that period.

Ratio Decidendi: For assessment years preceding an amendment that prospectively excludes a product from an exemption entry, the product remains covered by the earlier exemption if it falls within the ordinary scope of the exempted expression as judicially construed.

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