https://www.taxtmi.com/caselaws?id=105253 A fiscal levy must fall strictly within the charging provision, and cannot be justified by implication or broad statutory purpose; on that basis, the notification imposing additional toll tax on dry fruits exported out of the State was held to be beyond Section 3 of the Levy of Tolls Act and invalid. The Court also held that grading, sorting, bleaching, drying, shelling, separation, cleaning and packing of walnuts and other dry fruits did not amount to manufacture for exemption purposes, so the exemption claim failed. The decision underscores strict construction of taxing statutes and limits on treating processing activities as manufacture. en-us Wed, 17 Jul 2002 00:00:00 +0530 Mon, 12 Jan 2026 10:52:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=105253 A fiscal levy must fall strictly within the charging provision, and cannot be justified by implication or broad statutory purpose; on that basis, the notification imposing additional toll tax on dry fruits exported out of the State was held to be beyond Section 3 of the Levy of Tolls Act and invalid. The Court also held that grading, sorting, bleaching, drying, shelling, separation, cleaning and packing of walnuts and other dry fruits did not amount to manufacture for exemption purposes, so the exemption claim failed. The decision underscores strict construction of taxing statutes and limits on treating processing activities as manufacture. Case-Laws VAT / Sales Tax Wed, 17 Jul 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=105253