Plain meaning of exemption entry for paddy husk upheld; outer covering of paddy treated as a separate exempt commodity.

Paddy husk was treated as exempt under the cited notification because the expression covered de-oiled paddy husk and outer covering of paddy as separate descriptions. On the plain meaning of the words, de-oiled paddy husk means husk after oil extraction, while paddy husk simpliciter refers to the outer covering of paddy. The Tribunal's view that the two were different commodities was accepted, and the dealer's goods were held to fall within the exemption for outer covering of paddy. The impugned order was upheld and no question of law was found to arise.

---

---

Issues: Whether paddy husk sold by the dealer was exempt under Schedule I, Serial No. 4 of Notification dated 20 December 2007 as de-oiled paddy husk or outer covering of paddy.

Analysis: The expression in the notification was treated as covering de-oiled paddy husk or outer covering of paddy as separate descriptions. On the plain meaning of the words used, de-oiled paddy husk denotes husk after oil has been extracted, while paddy husk simpliciter means the outer covering of paddy. The Tribunal's view that these were different commodities was found to be correct, and the dealer's goods were held to fall within the expression outer covering of paddy.

Conclusion: The paddy husk sold by the dealer was held to be exempt, and the revision failed.

Final Conclusion: The impugned order was upheld and no question of law was found to arise.

---