Strict construction of tax exemptions keeps artificial silk outside a "foreign silk" notification and taxable.

An exemption notification must be construed strictly, so goods fall within it only if they are clearly described by its terms. Here, the Mysore sales tax notification exempted filature silk, foreign silk, and charka silk twisted by hand, and those expressions were understood to mean silk produced by the silk worm, not a silk-like substitute. Artificial silk, being non-genuine and merely resembling silk in appearance, could not be treated as "foreign silk" in the absence of clear language extending the exemption to such goods. Artificial silk was therefore outside the exemption and remained liable to sales tax.

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Issues: Whether artificial silk manufactured in foreign countries and imported into India fell within the exemption for "foreign silk" under the sales tax notification issued under the Mysore Sales Tax Act, 1948.

Analysis: The notification exempted the sale of filature silk, foreign silk, and charka silk twisted by hand from tax under Section 3(1) of the Mysore Sales Tax Act, 1948, as issued under Section 6 of that Act. The expression "artificial silk" was held to denote something not genuine or not real, and could not be treated as silk merely because it resembled silk in appearance or sheen. The terms used in the notification were taken to refer to silk produced by the silk worm, not to silk-like material. In the absence of clear language extending the exemption to non-silk goods, the notification could not be enlarged by interpretation.

Conclusion: Artificial silk was not covered by the exemption notification and was liable to sales tax.

Ratio Decidendi: An exemption notification must be construed strictly, and goods not clearly within the exempted description cannot be brought within it by treating a silk-like article as silk.

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