Functional reading of poultry feed exemption covers feed supplements with independent uses, and the tax appeal failed.

Feed supplements such as proteins, salts, minerals, vitamins, antibiotics and coccidiostats may qualify as "poultry feed" under an exemption entry when read in its commercial and functional sense. The stated principle is that an item need not be used exclusively as feed if it forms part of poultry nutrition within the exempted class. On that reasoning, the exemption could not be denied merely because the individual ingredients also have other uses, and the tax appeal was dismissed.

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Issues: Whether feed supplements such as proteins, salts, minerals, vitamins, antibiotics and coccidiostats could be treated as "poultry feed" under the exempting entry in Schedule B, and whether the Tribunal was justified in holding the sale exempt from tax.

Analysis: The entry for poultry feed was construed in the context of the object of exemption and the settled principle that an article falling within a tax entry need not be used only in an exclusive sense, but must answer the commercial and functional description intended by the provision. The reasoning accepted that feed supplements forming part of poultry nutrition would not be excluded merely because each constituent may also be capable of separate use. In exemption matters, once the assessee brings the case within the provision, the benefit follows, and no substantial question of law arose from the Tribunal's view.

Conclusion: The feed supplements were held to fall within the exempted category of poultry feed, and the tax appeal was dismissed.

Ratio Decidendi: A feed supplement may fall within an exempted feed entry if, on a functional and commercial reading, it is part of the class of poultry feed covered by the exemption, and the benefit of the exemption cannot be denied merely because individual constituents may also have independent uses.

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