Strict construction of exemption entries excludes Mehndi Cone from tax exemption as a distinct manufactured product.

Mehndi Cone was held outside Entry 23 of Schedule I to the Uttar Pradesh Value Added Tax Act, 2008 because the exemption covered only Mehndi leaves and Mehndi powder. The product was manufactured by processing Mehndi powder with oil, chemicals, preservative and water, giving it a distinct commercial identity. Since exemption entries are to be strictly construed, the wording could not be expanded to include derivative products not expressly named. The Tribunal's finding was upheld, and the assessee was denied exemption.

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Issues: Whether Mehndi Cone is covered by Entry 23 of Schedule I of the Uttar Pradesh Value Added Tax Act, 2008 so as to be exempt from tax.

Analysis: Entry 23 extends exemption only to Mehndi leaves and Mehndi powder. The product in question was admittedly manufactured by processing Mehndi powder with oil, chemicals, preservative and water, resulting in a distinct commercial product. A derivative product created through manufacturing cannot be treated as the same as the exempted raw material or powder. Exemption entries are to be strictly construed, and the wording of the entry could not be expanded to include all derivatives of Mehndi when the Legislature confined the benefit specifically to leaves and powder.

Conclusion: Mehndi Cone does not fall within Entry 23 of Schedule I and is not entitled to exemption; the finding of the Tribunal was upheld against the assessee.

Ratio Decidendi: An exemption entry limited to specified goods must be strictly construed, and a manufactured product having a distinct identity from the enumerated exempt goods is not covered by the entry unless expressly included.

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