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Issues: Whether a belt pulley attachment sold as a spare part was an agricultural implement within Entry 34 of Schedule 'B' of the Punjab General Sales Tax Act, 1948, so as to qualify for sales tax exemption prior to the amendment of 15 April 1971.
Analysis: The exemption entry covered agricultural implements, and the question was whether the item could properly be brought within that expression on the footing that it improved the utility of a tractor for agricultural operations. The item was shown to have multiple uses and was sold separately as a spare part for different machines, including non-agricultural appliances. The later amendment specifically inserting belt pulley attachment into the entry could not by itself establish that it was already included earlier. The expression in the exemption entry could not be stretched beyond its ordinary meaning to include an item of general mechanical use.
Conclusion: The belt pulley attachment was not an agricultural implement within Entry 34 prior to the amendment and was not exempt from sales tax.
Ratio Decidendi: An exemption for agricultural implements must be construed strictly, and an article of general mechanical utility sold as a spare part and capable of use in non-agricultural machinery does not fall within that exemption unless expressly included.
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