Literal interpretation of amended tax entry brought all dyes and chemicals into first-stage sales tax regardless of use.

The amended tax entry for dyes and chemicals was held to be clear and unambiguous, so the earlier limitation tying first-stage taxability to use in textile manufacture no longer applied. The Court gave literal effect to the amended language and declined to rely on interpretations drawn from grouped expressions such as "dyes and chemicals" when the statutory text itself was explicit. As a result, all types of dyes and chemicals were held taxable at the first stage of sale for all purposes, irrespective of their end use, and the issue was decided in favour of the Revenue.

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Issues: Whether, after the amendment introducing entry 49, all types of dyes and chemicals were liable to tax at the first stage of sale irrespective of their use.

Analysis: The entry as amended was held to be clear and unambiguous. The earlier condition limiting first-stage taxability to chemicals sold for use in manufacturing or processing of textile goods, supported by declaration form STD4, had been removed. The Court held that the principles applied in cases involving grouped expressions such as "dyes and chemicals" could not override the plain language of the amended entry. Where the statutory language is explicit, it must be given literal effect without searching for a different intention.

Conclusion: The amended entry covered all types of dyes and chemicals and made them taxable at the first stage of sale for all purposes, irrespective of their use. The issue was answered against the assessee and in favour of the Revenue.

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