Plain-language exemption for seeds includes rejected seeds; separate enactments cannot narrow a clear fiscal entry.

Rejected seeds fall within the plain expression "seeds of all kinds" in Entry 52 of Schedule I to the Uttaranchal Value Added Tax Act, 2005 and are exempt from tax. The VAT Act was applied on its own terms, and the exemption entry was treated as clear and unambiguous. The High Court declined to import limitations from the Seeds Act, 1966, because the two enactments operate in separate fields. Accordingly, the exemption was construed according to its ordinary meaning, extending to all seeds other than oil-seeds, without confining the entry to certified or selected seeds.

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Issues: Whether the expression "seeds of all kinds" in Entry 52 of Schedule I to the Uttaranchal Value Added Tax Act, 2005 covers rejected seeds and therefore exempts them from tax.

Analysis: The charging and exemption scheme of the 2005 Act was applied on its own terms. The Act treated goods listed in Schedule I as non-taxable, and the expression used in Entry 52 was held to be clear and unambiguous. The Court held that, as a fiscal statute, the VAT Act did not require recourse to the Seeds Act, 1966, because the two enactments operate in separate fields. On the plain language of the entry, all kinds of seeds, other than oil-seeds, were treated as exempt, and the expression was not confined to certified or otherwise selected seeds.

Conclusion: Rejected seeds are included within "seeds of all kinds" and are not liable to tax under Entry 52 of Schedule I.

Ratio Decidendi: In a fiscal statute, where the exemption entry is plain and unambiguous, the exemption must be given effect according to its ordinary meaning without importing limitations from another independent enactment.

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