Strict construction of tax exemption entries excludes examination answer-books from the meaning of exercise books.

Exemption entries must be construed strictly against the claimant, and words of common use are to be given their ordinary meaning. On that approach, an exercise book is a book used by students for school exercises, while an examination answer-book serves the distinct purpose of answering examination questions. Although both are paper commodities, they are not the same item, and the phrase "exercise books" could not be expanded to cover examination answer-books. They are therefore not exempt from sales tax under the relevant schedule entry.

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Issues: Whether examination answer-books are "exercise books" and therefore exempt from sales tax under entry 14 of Schedule I to the Madhya Pradesh General Sales Tax Act, 1958.

Analysis: The exemption entry had to be construed strictly against the person claiming exemption. Words of everyday use were to be understood in their common parlance meaning. In that sense, an exercise book is a book used by students for school exercises, whereas an examination answer-book is used for answering questions in an examination and serves a different purpose. Although both may be made of paper, they are not the same commodity, and the expression "exercise books" could not be enlarged to include "examination answer-books".

Conclusion: Examination answer-books are not exercise books and are not exempt from sales tax under entry 14 of Schedule I to the Madhya Pradesh General Sales Tax Act, 1958.

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