Unamended tax entry for moulded plastic footwear construed broadly; later clarification could not narrow coverage or VAT rate.

An unamended tax entry describing "moulded plastic footwears" was construed broadly to include both single-mould and multi-mould footwear, because the original wording contained no distinction or exclusion. A later amendment expressly referring to footwear "whether of single mould or more than one mould" was treated as clarificatory rather than as creating a new coverage. An administrative clarification under section 56(3) could not narrow the plain scope of the earlier entry. The Tribunal's view that the goods remained taxable at four per cent before 1 January 2007 was upheld, and no substantial question of law arose.

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Issues: Whether unamended entry 55 in Schedule C of the Haryana Value Added Tax Act, 2003 covered single-mould and multi-mould moulded plastic footwear, and whether the Tribunal was in holding that VAT at four per cent applied prior to 1 January 2007.

Analysis: The unamended entry described "moulded plastic footwears" without distinguishing between footwear made by a single mould or by more than one mould. The later substitution of the entry, expressly stating "whether of single mould or more than one mould", indicated that the amendment clarified the existing scope rather than creating a new exclusion. In the absence of any exclusion in the original wording, the entry had to be read broadly and the goods in question remained within Schedule C. The clarification issued under section 56(3) could not override the plain scope of the earlier entry where the statutory text itself did not support the narrower departmental view.

Conclusion: The Tribunal was right in holding that single-mould and multi-mould moulded plastic footwear were covered by the unamended entry 55 and were liable only to VAT at four per cent prior to 1 January 2007.

Final Conclusion: No substantial question of law arose, and the revenue appeal failed.

Ratio Decidendi: Where the original tax entry is unqualified and a later amendment merely clarifies its scope, the earlier entry must be construed according to its plain language and cannot be narrowed by an administrative clarification.

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