Ejusdem Generis Limits Agricultural Exemption for Coal Supply Under Income-tax Law

Section 14(3)(i)(d) of the Indian Income-tax Act, 1922 exempted a co-operative society only when it supplied agricultural implements, seeds, live-stock, or other articles of the same class intended for agriculture. Applying ejusdem generis, "other articles intended for agriculture" was confined to items directly required in agricultural operations and akin to the enumerated goods. Coal supplied for brick manufacture did not satisfy that test, even if the bricks were later used by agriculturists for wells, storage structures, irrigation channels, or houses. The supply was therefore outside the exemption, and the assessee was not entitled to relief.

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Issues: Whether income derived from the supply of coal to members was exempt under section 14(3)(i)(d) of the Indian Income-tax Act, 1922.

Analysis: The exemption in section 14(3)(i)(d) covered a co-operative society engaged in supplying agricultural implements, seeds, live-stock, or other articles intended for agriculture. Applying ejusdem generis, the expression "other articles intended for agriculture" was held to cover only articles directly required in connection with agricultural operations and of the same class as the enumerated items. Coal supplied for manufacture of bricks, even if those bricks were later used by agriculturists for wells, storage structures, irrigation channels, or dwelling houses, was not directly required for agricultural operations and could not be treated as an article intended for agriculture.

Conclusion: The assessee was not entitled to exemption under section 14(3)(i)(d); the question was answered in the affirmative and against the assessee.

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