Plain meaning of exemption notification extends State-owned company coverage for factory exemption under Notification No. 1/93.

A company wholly owned by the State Government may qualify as a factory "belonging to or maintained by" the State Government for exemption under Notification No. 1/93 when the notification is read according to its plain language. The analysis treats a Government company under section 617 of the Companies Act, 1956, with 100% State shareholding, as a fully owned State Government undertaking within the scope of Explanation VIII. Applying the plain-meaning approach to exemption notifications, the assessee was entitled to the exemption and the Department's challenge failed.

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Issues: Whether a company wholly owned by the State Government qualifies as a factory "belonging to or maintained by" the State Government for the purpose of exemption under Notification No. 1/93.

Analysis: The exemption turned on the language of Explanation VIII to Notification No. 1/93. The company was a Government company within Section 617 of the Companies Act, 1956, with 100% of its share capital held by the Kerala State Government. On that basis, it was treated as a fully owned State Government undertaking answering the description "belonging to or maintained by" the State Government. The interpretation adopted was consistent with the settled rule that exemption notifications are governed by their plain words.

Conclusion: The assessee was held entitled to the exemption, and the Revenue's appeal was dismissed.

Final Conclusion: The order granting exemption to the assessee was sustained, resulting in rejection of the Department's challenge.

Ratio Decidendi: A company wholly owned by the State Government can fall within an exemption meant for establishments "belonging to or maintained by" the State Government where the notification language so permits on a plain reading.

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