Strict construction of book-exemption notifications excludes trade catalogues and similar specialised publications from sales tax relief.

An exemption for "books meant for reading or reference" under the Kerala General Sales Tax Act is to be construed strictly, with the assessee bearing the burden of showing that the goods fall within the notification. Applying ordinary commercial meaning and noscitur a sociis, the expression was confined to printed books intended for public reading, education, knowledge or recreation, and did not extend to account books, diaries, catalogues, balance sheets, auction lists or similar trade publications used by a limited class. On that interpretation, specialised publications of that kind were outside the exemption and remained taxable.

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Issues: Whether catalogues, annual reports, annual statements of accounts, and a trade publication fell within the expression "books meant for reading or reference" in the exemption notification under the Kerala General Sales Tax Act, 1963.

Analysis: The exemption notification, issued in public interest under section 10 of the Kerala General Sales Tax Act, 1963, exempted "books, journals, magazines and weeklies", but its explanation confined "books" to printed books meant for reading or reference and excluded account books, note-books, diaries and the like. The burden to bring the goods within the exemption lay on the assessee. The expression had to be understood in its ordinary and common commercial sense, and by applying noscitur a sociis the words "reading or reference" indicated books meant for public use for education, knowledge, enlightenment or recreation. Publications used mainly as catalogues, balance sheets, auction lists, or trade material for a limited class of persons were not treated as books of the kind contemplated by the notification.

Conclusion: The publications in question were not "books meant for reading or reference" and were not exempt from sales tax.

Ratio Decidendi: An exemption notification for "books meant for reading or reference" is to be construed strictly, and only books ordinarily understood as literary or public reading material fall within it, not trade catalogues or similar specialized publications.

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