Powerloom cloth as mill-made textile qualifies for sales tax exemption when manufactured in a factory.

Cloth manufactured on powerlooms in a factory was treated as "mill-made textile" for purposes of exemption under section 5A(1)(i) of the General Sales Tax Act, 1125. The court construed the expression by contrast with handloom textiles and accepted that "mill" can denote a factory or building housing machinery. Because the goods were produced with the aid of powerlooms situated in a factory, they fell within the exempt category. The contrary view that powerloom cloth cannot qualify as mill cloth was rejected, and the assessee obtained the exemption.

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Issues: Whether cloth manufactured on powerlooms and housed in a factory falls within the expression "mill-made textile" under section 5A(1)(i) of the General Sales Tax Act, 1125, so as to qualify for exemption from sales tax.

Analysis: The expression "mill-made textile" was construed by reference to the statutory distinction between textiles made by handlooms and those made with the aid of machinery. The word "mill" was understood as capable of bearing either a machinery-based sense or a popular sense referring to a factory or building housing machines. On the facts, the cloth was manufactured with the aid of powerlooms situated in a factory, and therefore answered the description of mill-made textile. The contrary view that powerloom cloth cannot be treated as mill cloth was not accepted.

Conclusion: The cloth manufactured by powerlooms in a factory is exempt under section 5A(1)(i) as mill-made textile, and the revision was allowed in favour of the assessee.

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