2016 (4) TMI 1186

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.... present appeal is directed against order dated 24.02.2015 passed by the Advance Ruling Authority, in exercise of power under Section 60(4) of the Karnataka Value Added Tax, 2003 (hereinafter referred to as 'the KVAT Act' for brevity), whereby the material which is being purchased and sold by the appellant is excluded from entry No.71 and the rate s are specified. 4. We have heard Mr. M.N. Shankare Gowda, learned Counsel appearing for the appellant and Mr. K.M. Shivayogiswamy, learned Addl. Government Advocate, appearing for the respondent. 5. It appears that the appellant is dealing in the printing of hoardings and banners. On 31.08.2012 the appellant raised an invoice by showing description of the commodity as Poster and levied VAT ....

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....books, paper envelopes, diaries, calendars, race cards, catalogues, greeting cards, invitation cards, humour post cards, picture post cards, cards for special occasions, photo and stamp albums, computer stationery." The aforesaid shows that the printed material other than books are included but stationery articles of various categories viz., account books, paper envelopes, diaries, calendars, race cards, catalogues, greeting cards, invitation cards, humour post cards, picture post cards, cards for special occasions, photo and stamp albums and computer stationeries are provided. If one has to consider the entry, the entry is always to be considered after reading it as a whole and it cannot be by segregating a few words of the entry. A rea....

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....would be redundant. For example, printed garments, printed sarees, printed wall papers and various other printed items though may be falling in the respective entries, would be rendered otiose. In interpretation of an entry in a taxing statute even if the meaning understood in commercial parlance is considered, then also, the items which are included in Entry No.71 cannot encompass the items of printed banners and hoardings. In all respects, the items which are included in Entry No.71 are altogether different from that of the items of the appellant for which the rates are prescribed by the Advance Ruling Authority by way of a clarification. 10. Learned Counsel for the appellant did contend that the Advance Ruling Authority has not examin....