Common parlance test expands book exemption to account books, note-books and similar records under a sales tax notification.

Broad exemption language in a sales tax notification was construed in its ordinary and popular sense, not as limited to literary reading matter. Because the notification superseded an earlier narrower one, the phrase "all books and periodicals" was held to include every kind of book, including account books, note-books, ledgers and journals. Applying the common parlance test and the rule that a taxing exemption must be read according to the language used, the exemption extended to turnover from sales of such books, and the revisional challenge failed.

---

---

Issues: Whether the expression "all books and periodicals" in the exemption notification issued under section 9(1) of the Andhra Pradesh General Sales Tax Act, 1957 included account books, note-books, ledgers, journals and similar non-literary books.

Analysis: The exemption notification used broad language and superseded an earlier notification that had exempted only specified categories of books. The words "all books" were construed in their ordinary and popular sense, not in a restricted literary sense. Applying the common parlance test and the rule that a taxing exemption must be read according to the language used, the expression was held to cover every kind of book, including account books and note-books, and not merely books of reading matter.

Conclusion: The exemption applied to the petitioners' turnover from sales of account books, note-books and similar books, and the revisions were allowed.

---