Exemption notification interpreted broadly to cover both sale tax on castor oil and purchase tax on castor seeds.

Exemption under Notification II of G.O. No. 1091 was interpreted to cover persons dealing exclusively in single country oil ghanis or hand oil presses. The phrase "any tax under the said Act in respect of such dealings" was given its ordinary breadth, and "such dealings" was read to include both the sale of castor oil and the purchase of castor seeds used to produce it. As no limiting language confined the benefit to sales tax alone, the exemption applied to tax on both the sale value of the oil and the purchase value of the seeds, rendering the demand unsustainable to that extent.

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Issues: Whether the exemption granted by Notification II of G.O. No. 1091 Revenue dated 10th June, 1957, to persons owning and dealing exclusively in single country oil ghanis or hand oil presses extends only to tax on the sale of castor oil or also covers tax on the purchase value of castor seeds used in producing the oil.

Analysis: The notification exempted eligible assessees from payment of "any tax under the said Act in respect of such dealings". The Court held that, although exemption provisions are to be construed strictly, their actual language must be given effect. The phrase "any tax" was treated as comprehensive and not confined to sales tax alone. The expression "such dealings" was read broadly enough to include not merely sale of the produce but also the purchase of the raw seeds without which the oil could not be extracted. In the absence of language limiting the exemption to tax at the sale point, there was no justification to restrict the notification to sales tax alone.

Conclusion: The exemption covered both the tax on the sale of castor oil and the tax on the purchase value of the castor seeds, and the demand to that extent was not sustainable.

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