Processed de-oiled rice bran used as animal feed is classified under the exemption entry, not taxable raw bran.

De-oiled rice bran, after processing and sale as poultry feed, cattle feed and feed supplement, was treated as animal feed rather than raw husk or bran of cereals and pulses. The First Schedule entry for animal feed and feed supplements applied because the commodity had undergone processing and was used as feed, while the Third Schedule entry covered only unprocessed husk and bran. Where the competing classifications were capable of two views, the exemption entry was applied in favour of the assessee. The commodity was therefore held eligible for tax exemption under the First Schedule, not taxable under the Third Schedule.

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Issues: Whether de-oiled rice bran sold as animal feed or feed supplement falls under the First Schedule as exempt goods or under the Third Schedule as taxable husk and bran of cereals and pulses.

Analysis: De-oiled rice bran was found to be a processed commodity obtained after extraction of oil from rice bran and sold for use in poultry feed, cattle feed, and feed supplements. The entries in the First Schedule covered animal feed and feed supplements, including processed commodities sold as poultry feed and cattle feed, while the Third Schedule covered only husk and bran of cereals and pulses. The commodity in question did not remain mere husk or bran after processing, and the exemption entry had to be applied in favour of the assessee where the classification was capable of two views. The assessee's business records and sales pattern also supported its use as feed supplement rather than as raw bran.

Conclusion: De-oiled rice bran fell under the First Schedule and was entitled to exemption from tax, not under the Third Schedule.

Ratio Decidendi: A processed commodity sold and used as animal feed or feed supplement is ifiable under the exemption entry for animal feed and feed supplements, and not under the taxable entry for raw husk or bran, where the taxing entries are ambiguous.

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