Strict construction of quarrying exemption notification bars sales tax relief on outright sale of quarried products.

A sales tax exemption notification covering "earthwork, laterite, metal, sand, jelly and gravel quarrying contracts" was construed strictly according to its clear terms. The exemption applied only to quarrying contracts relating to the specified materials, not to the subsequent outright sale of quarried metal, gravel, rubbish or similar products. Because the assessee's transactions were sales of quarry products rather than exempt quarrying contracts, the claimed relief from sales tax was unavailable. The exemption could not be extended beyond the express language of the notification.

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Issues: Whether the assessee's sales of metal, gravel, rubbish and similar quarry products were exempt from sales tax under the Government notification issued under section 6(1) of the Madras General Sales Tax Act, 1939.

Analysis: The notification exempted "earthwork, laterite, metal, sand, jelly and gravel quarrying contracts" from tax. The language of the notification was held to be clear and unambiguous, and it was construed as exempting only quarrying contracts relating to the specified materials, not the subsequent outright sale of the quarried goods. The exemption could not be extended beyond the express terms of the notification.

Conclusion: The assessee's sales were not covered by the exemption, and the claim to relief from sales tax failed.

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