Tax exemption for foreign-made fabrics cannot be narrowed by implication where the schedule states no extra condition.

Foreign-made woollen and artificial silk fabrics fell within entry 4 of the Third Schedule to the Tamil Nadu General Sales Tax Act, 1959, so their sales were exempt under section 8. The Court held that section 8 exempts the goods specified in the Schedule and permits restrictions only if prescribed by rules; the schedule entry itself did not add a requirement that the fabrics must have been manufactured in India or liable to central excise. Legislative materials could not read in such a limitation, and rule 6(a) imposed no narrowing condition. The assessee's turnover was therefore not taxable on that basis.

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Issues: Whether sales of foreign-made woollen and artificial silk fabrics were exempt from sales tax under section 8 read with entry 4 of the Third Schedule to the Tamil Nadu General Sales Tax Act, 1959, and whether the entry could be read as confining the exemption only to fabrics manufactured in India or liable to central excise.

Analysis: Section 8 grants exemption to goods specified in the Third Schedule and makes the exemption subject only to such restrictions and conditions as may be prescribed. The Court held that the Third Schedule identifies the exempt goods, while the rules alone may prescribe conditions and restrictions. Entry 4 merely describes the exempt fabrics by reference to the corresponding items in the First Schedule to the Central Excises and Salt Act, 1944, and does not itself impose any additional condition that the fabrics must have been manufactured in India or must have borne central excise duty. The amendment to entry 4 did not alter the structure of section 8, and legislative materials such as objects and reasons could not be used to read in a limitation absent from the statutory text. The Court also noted that rule 6(a) did not prescribe any restriction narrowing the exemption.

Conclusion: The foreign fabrics answered the description in entry 4 and were entitled to exemption; the assessee's sales turnover could not be taxed on that basis.

Ratio Decidendi: Where a taxing exemption provision specifies the exempt goods and leaves conditions and restrictions to be prescribed by rules, the description in the schedule cannot be enlarged by implication to add unexpressed limitations on the exemption.

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