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Issues: Whether poha and murmura, though separately taxable under the State Act, were covered by the exemption notification granting exemption to cereals specified in clause (i) of Section 14 of the Central Sales Tax Act, 1956.
Analysis: The notification issued under Section 12 of the Madhya Pradesh General Sales Tax Act, 1958 exempted cereals specified in clause (i) of Section 14 of the Central Sales Tax Act, 1956. The expression "cereals" in that provision was understood to include rice and forms of rice such as beaten rice and puffed rice. The separate entry created in the State Act for taxation purposes did not control the scope of the exemption notification. Exigibility to tax and entitlement to exemption were treated as distinct concepts, and the notification had to be applied on its own language and object.
Conclusion: Poha and murmura were held to be covered by the exemption notification and entitled to exemption from tax.
Final Conclusion: The writ petitions succeeded to the extent that the assessment was set aside for reconsideration in accordance with the exemption declared applicable to poha and murmura.
Ratio Decidendi: Where an exemption notification adopts the description of goods in a central statutory entry, the exemption must be determined by that description and not by a separate taxable entry in the State schedule; rice includes its common processed forms such as poha and murmura.