Intended use governs agricultural exemption for tractor trailers; dealer sales do not defeat relief where actual use need not be proved.

An exemption entry covering agricultural implements notified by the State, including tractor trailers for use in agricultural purpose, was construed by the court to turn on intended use rather than direct sale to agriculturists. The phrase "for use" was read as "intended for use", so the dealer or distributor route did not defeat exemption and proof of actual end use was unnecessary. On that basis, the denial of exemption was held incorrect, and the tax demand and concurrent adverse orders were set aside.

---

---

Issues: Whether tractor trailers sold to dealers/distributors, and not directly to agriculturists, were entitled to exemption from tax as tractor trailers for use in agricultural purpose under the relevant entry and notification.

Analysis: The exemption entry covered agricultural implements notified by the State Government, and the notification specifically included tractor trailers for use in agricultural purpose. The expression "for use" was construed to mean "intended for use", so the decisive question was the intended agricultural use of the trailers, not whether they were sold directly to agriculturists or through dealers/distributors. Actual use by the end purchaser was not required to be proved for the exemption.

Conclusion: The trailers were eligible for exemption, and the denial of exemption on the ground that the sales were routed through dealers/distributors was incorrect.

Final Conclusion: The tax demand and the concurrent orders denying exemption were set aside, and the assessee succeeded in the appeal.

Ratio Decidendi: Where an exemption entry uses the expression "for use", the relevant test is intended use, not actual use or direct sale to the ultimate user, unless the statute expressly requires otherwise.

---