Bread classification rules place rusk and toast within the specific entry, not the residuary category.

Rusk and toast were treated as retaining the essential character of bread for classification under the Chhattisgarh Value Added Tax Act, 2005. The term "bread" in Entry 7 of Schedule I was read in its generic and common-parlance sense, and the minor differences in baking time and moisture content were held insufficient to move the products to the residuary entry. Applying the rule that a specific entry prevails over the residuary entry, the burden lies on the Revenue to justify exclusion, and ambiguity is resolved in favour of the assessee, the products were classified as bread rather than under Part IV of Schedule II.

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Issues: Whether rusk and toast fall within Entry 7 of Schedule I as bread under the Chhattisgarh Value Added Tax Act, 2005, or are classifiable under the residuary entry in Part IV of Schedule II.

Analysis: The term "bread" in Entry 7 was treated as a generic expression. The basic ingredients of bread, toast, and rusk were found to be substantially the same, and the principal distinction lay only in the duration of baking and resultant moisture content. Applying the settled principles that a specific entry must be preferred over the residuary entry, that the burden to justify resort to the residuary entry lies on the Revenue, and that where two views are possible the one favourable to the assessee should be adopted, the Court held that rusk and toast retain the essential character of bread. The Court also relied on the common parlance and commercial understanding of the products and on the absence of convincing evidence from the Revenue to exclude them from the bread entry.

Conclusion: Rusk and toast fall within Entry 7 of Schedule I as bread and do not attract the residuary entry in Part IV of Schedule II.

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