Broad exemption for "all books" covered printed materials, and reopening notices based on a narrow reading failed.

The expression "all books" in the exemption notification under the Andhra Pradesh General Sales Tax Act was construed broadly to cover every kind of book, not merely literary or reading matter, and that settled interpretation had been accepted for decades. The Court noted that the State later modified the exemption by a subsequent government order, reinforcing the earlier understanding. On that basis, the disputed printed materials, including C form books, lottery tickets and share certificates, fell within the exemption, and the reopening notices based on a narrower reading were not liable to be interfered with.

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Issues: Whether the expression "all books" in the exemption notification issued under the Andhra Pradesh General Sales Tax Act, 1957 included C form books, lottery tickets, share certificates and similar printed material, so as to keep the reopening notices unsustainable.

Analysis: The notification exempted sales of "all books and periodicals" from tax, and the expression had already been construed by the High Court in earlier litigation to cover every kind of book, not merely literary or reading matter. That construction had held the field for nearly three decades, and the State had subsequently altered the exemption by a later government order, which indicated acceptance of the earlier understanding. In these circumstances, the Court declined to disturb the settled meaning of the notification or reopen the completed assessments on the contrary premise.

Conclusion: The expression "all books" was held to be wide enough to include the disputed printed materials, and the reopening notices were not liable to be interfered with.

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