Concessional sales tax for woollen ready-made garments upheld under the notification scheme for textile items.

Woollen ready-made garments were covered by the concessional sales tax rate under the relevant notification scheme, because the notifications had to be read together and the later notification did not alter the earlier rate structure for listed textile items. Item 13 of the earlier notification was construed as separately including ready-made garments of wool, while the qualifying words applied only to the last category concerning silk and other textile fabrics with gold, silver or gilded metal. On that construction, woollen coats fell within the concessional entry and were not liable at the general rate.

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Issues: Whether woollen coats falling within ready-made garments were chargeable to sales tax at the general rate or at the concessional rate prescribed by the relevant notification scheme.

Analysis: The notifications had to be read together, because the later notification amended the earlier rate structure for the listed textile and garment items. Item 13 of the earlier list specifically covered ready-made garments made of silk, wool, or other textile fabrics in which gold, silver or gilded metal was used, and the qualifying words governed only the last category. On that construction, ready-made garments of wool were separately included within the concessional item. The later notification did not displace that interpretation and, read in the background of the earlier notifications, continued the lower rate for woollen ready-made garments.

Conclusion: The turnover of woollen coats was chargeable at the concessional rate applicable to ready-made garments of wool, and not at the general rate.

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