Exemption must be confined to express terms: gingelly seed purchases were not covered, so purchase tax applied.

Purchase turnover of gingelly seeds remained liable to purchase tax because the exemption in the Government Orders was confined to the express subject matter covered by their language. Section 7-A of the Tamil Nadu General Sales Tax Act, 1959 applied, and there was no Government Order under section 17 exempting gingelly seed purchases. The Tribunal could not extend exemptions granted for sales of specified country oil chekku products, or for certain groundnut kernel purchases, to a different transaction on the basis of perceived public welfare. The purchase tax was therefore rightly leviable.

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Issues: Whether the purchase turnover of gingelly seeds was exempt from purchase tax merely because the Government Orders exempted sales of country oil chekku products and certain related purchases.

Analysis: Section 7-A of the Tamil Nadu General Sales Tax Act, 1959 applied to the purchase of gingelly seeds. The relevant Government Orders exempted only the sales of specified country oil chekku products, and one later order extended exemption to certain purchases of groundnut kernel, but there was no Government Order under section 17 exempting the purchase turnover of gingelly seeds. The Tribunal erred in treating the perceived public welfare object behind the Government Orders as a basis for extending the exemption to a different subject matter not covered by the language of the orders. A statutory body cannot expand the scope of an exemption beyond the express terms used by the Government.

Conclusion: The purchase turnover of gingelly seeds was not exempt, and the purchase tax was rightly leviable.

Ratio Decidendi: An exemption granted by a Government Order or taxing instrument must be confined to its express terms, and a tribunal cannot extend it to other transactions on supposed policy or welfare considerations.

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