Strict construction of sales tax exemption upheld where country bricks and tiles were not made by eligible village artisans or co-operatives.

The exemption notification under the Tamil Nadu General Sales Tax Act was construed strictly, and the Court held that it did not cover country bricks and country tiles manufactured by the petitioner's members unless they were produced by village artisans or co-operative societies. The amended language could not be read grammatically to dispense with that requirement, because such an interpretation would defeat the object of the exemption, which was intended to assist poor village artisans. The Court accepted the High Court's interpretation and declined interference, so the exemption remained unavailable to the petitioner's members.

---

---

Issues: Whether the exemption notification under the Tamil Nadu General Sales Tax Act, 1959 applied to country bricks and country tiles manufactured by the petitioner's members, and whether the requirement that the goods be produced by village artisans or co-operative societies was inapplicable.

Analysis: The notification, as amended, was construed in the setting of its object and language. The expression used could not grammatically be read as dispensing with the requirement that the goods be produced by village artisans or co-operative societies. Such a reading would also defeat the purpose of the exemption, which was intended to assist poor village artisans. Exemptions from tax are to be strictly construed, and the Court found the High Court's interpretation to be correct.

Conclusion: The exemption did not extend to the petitioner's members, and the challenge to the High Court's refusal to interfere failed.

---