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    <title>2009 (7) TMI 1185 - GAUHATI HIGH COURT</title>
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    <description>A power tiller was treated as an agricultural implement under the Assam VAT Schedule because agricultural operations were read broadly to cover activities connected with cultivation and making produce market-ready. Its incidental non-agricultural utility did not prevent classification under the specific agricultural-implements entry. The later express insertion of &quot;power tillers&quot; in a separate entry was not treated as conclusive proof that they were previously excluded. Ambiguity in the taxing provision was resolved in favour of the taxpayer, and the department was required to justify resort to the residuary entry.</description>
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      <description>A power tiller was treated as an agricultural implement under the Assam VAT Schedule because agricultural operations were read broadly to cover activities connected with cultivation and making produce market-ready. Its incidental non-agricultural utility did not prevent classification under the specific agricultural-implements entry. The later express insertion of &quot;power tillers&quot; in a separate entry was not treated as conclusive proof that they were previously excluded. Ambiguity in the taxing provision was resolved in favour of the taxpayer, and the department was required to justify resort to the residuary entry.</description>
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