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    <title>1978 (2) TMI 184 - Supreme Court</title>
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    <description>Atukulu and muramaralu were held to fall within the statutory expression &quot;rice&quot; in entry 66(b) of the Andhra Pradesh General Sales Tax Act. The Court reasoned that parching and puffing change only the form of the commodity, not its essential identity, and that the scheme did not create a separate taxable category for rice so processed. It also applied the settled rule of strict construction in favour of the assessee where a taxing entry is reasonably open to two meanings, particularly where a narrower view would create an unfair second incidence of tax on the same commodity. The levy was therefore not sustainable on the contrary interpretation.</description>
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    <pubDate>Tue, 21 Feb 1978 00:00:00 +0530</pubDate>
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      <title>1978 (2) TMI 184 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=101630</link>
      <description>Atukulu and muramaralu were held to fall within the statutory expression &quot;rice&quot; in entry 66(b) of the Andhra Pradesh General Sales Tax Act. The Court reasoned that parching and puffing change only the form of the commodity, not its essential identity, and that the scheme did not create a separate taxable category for rice so processed. It also applied the settled rule of strict construction in favour of the assessee where a taxing entry is reasonably open to two meanings, particularly where a narrower view would create an unfair second incidence of tax on the same commodity. The levy was therefore not sustainable on the contrary interpretation.</description>
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      <pubDate>Tue, 21 Feb 1978 00:00:00 +0530</pubDate>
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