Paddy husk and rice husk are distinct commodities; first-purchase tax did not apply under the earlier notifications.

Paddy husk was treated as distinct from rice husk for purposes of the taxing notifications. Reading the earlier notifications in light of later entries that separately referred to rice husk and paddy husk, the Court accepted that the later notifications clarified the pre-existing distinction rather than altering the law. The commodity purchased by the dealer was therefore identified as paddy husk, not rice husk. On that basis, it was not taxable at the first purchase under the earlier notifications, and the revisions failed.

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Issues: Whether paddy husk is the same as rice husk and therefore taxable at the first purchase under the relevant notifications.

Analysis: The taxing notifications were read in the light of later notifications which separately referred to rice husk and paddy husk. On that basis, the commodity purchased by the dealer was held to be the outer covering of paddy and not rice husk. The Court accepted the view that rice husk is a different commodity and that the later notifications clarified the earlier entry rather than changed the law. The distinction drawn by the Tribunal between paddy husk and rice husk was therefore sustained.

Conclusion: The commodity purchased was paddy husk and not rice husk. It was not taxable at the first purchase under the earlier notifications, so the revisions failed.

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