Ordinary meaning governs exemption notification for reading books; publications intended for reading fall within the exemption.

An exemption notification covering "sales of reading books including text-books" was construed by its ordinary meaning, with the phrase read as "books for reading." The HC held that no additional restriction could be imported from section 17 or the notification preamble, because the language of the item itself supplied the governing limit. Publications intended to be read, even by a limited audience, fell within the exemption, while items such as diaries or copying books would not. On that construction, the publications in question were treated as exempt under item 22 of the schedule.

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Issues: Whether the publications in question fell within item 22 of the schedule to the exemption notification covering sales of reading books including text-books.

Analysis: The relevant notification used the expression "sales of reading books including text-books". The phrase was construed according to its ordinary meaning, as the words of the notification themselves supplied the governing limit. The Court held that the expression should be understood as "books for reading", and that no further restriction could be introduced from section 17 or the preamble to the notification. Publications intended to be read, even by a limited section of the public, could still answer the description, though certain kinds of books such as diaries or copying books would not. On that construction, the publications concerned were held to be within the exemption.

Conclusion: The publications fell within item 22 of the schedule to the notification and were exempt.

Ratio Decidendi: An exemption notification must be construed according to the ordinary meaning of its words, and where the notification covers "reading books", publications meant for reading fall within it unless the language itself clearly excludes them.

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