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Coconut Oil Tax Exemption: Burden of Proof on Claimant; Ambiguities Favor Revenue, Not Assessee.
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....Benefit of exemption - Classification of the coconut oil sold by the appellant - It is settled law that a person claiming exemption has to establish that the product squarely falls within the category of exempted goods. It is also settled that while interpreting the exemption notification / statute, a consideration in favour of the Revenue has to be given and in case of ambiguity, the same has to be interpreted against the assessee. - HC....