Broad reading of "newspaper" for sales tax exemption covers weeklies and magazines carrying news and current topics.

Weeklies, magazines and similar periodicals were treated as "newspapers" for the constitutional sales tax exemption because the term was read broadly, informed by the Indian Post Office Act, 1898, and the rule that a tax exemption should favour the subject where two constructions are possible. Publications containing news, pictorial news, current topics and similar matter therefore fell within the wider understanding of newspapers and were not liable to State sales tax. On that approach, the assessee's deduction could not be reduced by 15 per cent.

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Issues: Whether weeklies, magazines and similar periodicals were "newspapers" within the meaning of the constitutional exemption from State sales tax, so as to entitle the assessee to full deduction on sales of those publications.

Analysis: The Constitution did not define "newspaper". The interpretation was informed by the more liberal statutory understanding in the Indian Post Office Act, 1898, under which a publication consisting wholly or in great part of political or other news, or articles relating thereto or to current topics, is treated as a newspaper for registration purposes. In a taxation matter, where two constructions are possible, the one more favourable to the subject was preferred. On that approach, the publications in question, being weeklies and magazines containing news, pictorial news, current topics and similar matter, fell within the wider understanding of newspapers and were not liable to State sales tax.

Conclusion: The publications were treated as newspapers for the purpose of the constitutional exemption, and the deduction could not be reduced by 15 per cent. The assessee succeeded.

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