Strict construction of tax exemption notifications confined concessional sales tax to gold bullion, not silver bullion.

Concessional sales tax under the Government notifications was confined to gold bullion and gold specie, not silver bullion. The Court read the term "bullion" in the schedule as including gold or silver in mass, but held that the notification's phrase "bullion and specie (gold)" showed a clear intention to limit the concession to gold only. The bracketed word "gold" could not be confined to specie alone, and the later omission of that word in a subsequent notification could not alter the position for the disputed period. Exemption notifications must be strictly construed, and no additional words may be read in to enlarge the concession.

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Issues: Whether the concessional rate of sales tax under the Government notifications applied to silver bullion as well as gold bullion and specie, and whether the reassessment levying tax at the higher rate was sustainable.

Analysis: Item 20 of the First Schedule and its explanation show that bullion includes gold or silver in mass, while specie refers to coined metal. The notification reducing tax referred to "bullion and specie (gold)", which made the Government's intention clear that the concession was confined to gold bullion and gold specie. The bracketed word "gold" could not be read as qualifying only specie, and the later omission of that word in a subsequent notification effective from a later date could not govern the disputed period. Exemption notifications must be construed strictly, and where the language is clear, no additional words can be read in to extend the concession.

Conclusion: The concessional rate was not available to silver bullion. The reassessment was upheld and the challenge failed.

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