Exemption notifications must be read on their own terms; departmental circulars cannot restrict statutory exemption claims.

A departmental circular may guide the assessing authority, but it cannot curtail an assessee's entitlement under an exemption notification. Each exemption notification must be construed strictly on its own language and conditions, and the assessee can claim exemption if those conditions are satisfied, regardless of the departmental view taken for assessment. The Court found that the High Court failed to address the correct question of law arising from the revisions. The impugned judgment was set aside and the matters were remitted for fresh decision by the assessing authority in accordance with law, without being influenced by the earlier departmental directions.

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Issues: Whether the assessee was bound by the Commissioner's circulars while claiming exemption under the relevant sales tax notifications, and whether the matter required fresh consideration on the terms of the exemption notifications.

Analysis: The dispute concerned the construction of exemption notifications and not merely classification for exigibility to tax. The Court held that the effect of a circular or departmental direction on the assessing authority does not control the assessee's entitlement under the notification. Each exemption notification must be read on its own terms, and the assessee is entitled to rely upon the notification if the stated conditions are satisfied, irrespective of the departmental view adopted for assessment purposes. The High Court, therefore, failed to address the correct question of law arising from the revisions.

Conclusion: The assessee was not bound by the Commissioner's circulars, and the claim for exemption had to be examined independently on the language and conditions of the notifications.

Final Conclusion: The impugned judgment was set aside and the matters were sent back for fresh decision by the assessing authority in accordance with law, without being influenced by the earlier departmental directions.

Ratio Decidendi: A departmental circular may bind the assessing authority, but it cannot curtail an assessee's statutory entitlement under an exemption notification, which must be construed strictly according to its own terms.

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