Exemption entries prevail over subordinate notifications when the legislature has already covered the goods in the exempt schedule.

Dried singhada remained covered by the exemption in Schedule I of the Madhya Pradesh Vanijyik Kar Adhiniyam, 1994, because the legislative entry for singhada was not displaced by a later notification placing it in Schedule II. The State Government's power under section 15(2) extended only to including additional goods in Schedule I or to relaxing or omitting conditions attached to an exempt entry; it did not permit exclusion of an item already protected by the schedule. A notification or clarificatory circular could not override or narrow the legislative exemption, and the attempt to tax dried singhada was ineffective.

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Issues: Whether dried singhada, treated by notification as falling in Schedule II, remained exempt as singhada under Schedule I of the Madhya Pradesh Vanijyik Kar Adhiniyam, 1994, and whether the State Government could curtail the scope of the exemption by notification.

Analysis: The exemption entry in Schedule I covered singhada, while Schedule II dealt with taxable goods. Section 15(2) of the Act empowered the State Government only to include additional goods in Schedule I or to relax or omit conditions and exceptions attached to an exempt entry. That power did not authorise the State Government to exclude an item already covered by the legislative schedule. The wording of the entry, especially the Legislature's use of an express exclusion in respect of dried ginger in the same entry, showed that no similar exclusion was intended for dried singhada. A notification or clarificatory circular could not override or narrow the legislative exemption.

Conclusion: Dried singhada remained covered by the exemption in Schedule I and the notification treating it as taxable was beyond the statutory power and ineffective against the legislative entry.

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