Tax notification interpreted by its own words: "light commercial vehicles" qualified for concessional tax without importing another statute's definition.

A sales tax notification granting a concessional rate for "light commercial vehicles" had to be construed on its own words and commercial context. The Court declined to import the definition of "light motor vehicle" from the Motor Vehicles Act, 1939 because the notification did not refer to that statute or impose a use-based limitation. As the respondents' vehicles were understood in trade and by the Government as light commercial vehicles, they fell within the notification and qualified for the concessional rate. The revenue's contrary reading was rejected because it would create an unsupported tax distinction based on intended use.

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Issues: Whether the expression "light commercial vehicles" in the sales tax notification covered the respondents' vehicles and entitled them to the concessional rate of tax, or whether the definition of "light motor vehicle" in the Motor Vehicles Act, 1939 had to be imported to restrict the benefit.

Analysis: The notification used the expression "light commercial vehicles" and did not refer to light motor vehicles used for commercial purposes. The respondents manufactured vehicles described as light commercial vehicles under government licences, and the trade and the Government of India understood that expression in that sense. The Court held that the words in the sales tax notification had to be read as used in that notification itself and there was no justification for importing the definitions from the Motor Vehicles Act, 1939. The Court also noted that the revenue's interpretation would lead to an anomalous tax distinction based on intended use, although the notification contained no such requirement.

Conclusion: The expression "light commercial vehicles" included the respondents' vehicles, and the concessional rate under the notification was applicable.

Final Conclusion: The sales tax authorities' challenge to the Tribunal's interpretation failed, and the appeals were dismissed with costs.

Ratio Decidendi: A tax notification must be construed according to the words used in it, in their commercial and contextual sense, and definitions from another statute cannot be imported unless the notification itself so requires.

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