Strict construction of tax exemptions excludes power sprayers from Schedule I and places them in taxable schedules.

Exemption entries in Schedule I of the Rajasthan Value Added Tax Act, 2003 were construed strictly on their express language, and the phrase "sprayer including their parts and accessories" was not treated as covering power sprayers. As no specific Schedule I entry included power sprayers, they could not obtain exemption by broad interpretation. Goods not specifically covered by an exempt entry were treated as falling within the taxable schedules under the statutory scheme, with Schedule IV applying to agricultural implements other than those listed in Schedule I and Schedule V applying to goods not covered elsewhere. Power sprayers were therefore taxable under Schedule IV, and their parts and accessories under Schedule V.

---

---

Issues: Whether power sprayers and their parts and accessories fall within the exempt entry for sprayers under Schedule I of the Rajasthan Value Added Tax Act, 2003, or are taxable under Schedule IV and Schedule V.

Analysis: The exemption entries in Schedule I were construed on their plain language. The expression "sprayer including their parts and accessories" was held not to be synonymous with "power sprayers and its parts and accessories". Since no specific entry in Schedule I covered power sprayers, they could not claim exemption merely by broad interpretation. The Court also treated goods not specifically covered by any exempt entry as falling within the taxable schedules, and relied on the statutory scheme of Schedule IV for agricultural implements other than those mentioned in Schedule I, and Schedule V for goods not covered elsewhere.

Conclusion: Power sprayers were held not to be exempt under Schedule I. They were taxable under Schedule IV, and their parts and accessories were taxable under Schedule V. The revision petitions were therefore rejected.

Ratio Decidendi: A taxing exemption entry must be construed strictly on its express language, and a goods classification cannot be extended by implication to cover an item not specifically included.

---