Strict construction of sales tax exemptions excludes a maize, rice bran and molasses mixture from cattle feed relief.

An exemption notification under the Tamil Nadu General Sales Tax Act must be construed strictly, so relief applies only to commodities squarely covered by the specific wording used. A mixture made from maize, rice bran and molasses was not among the cattle feed items expressly exempted, and the separate maize notification did not extend to the mixture or exempt maize in that form. The commodity therefore fell outside the notification and remained taxable.

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Issues: Whether the mixture of maize with rice bran and molasses was entitled to exemption under the relevant sales tax notification.

Analysis: The notification issued under section 17(1) and (3) of the Tamil Nadu General Sales Tax Act, 1959 granted exemption only to specified cattle feed items such as hay, straw, rice bran, husk, and dust of pulses and grams. The commodity sold by the assessee was a mixture manufactured out of maize, rice bran, and molasses. The exemption could not be extended beyond the precise items named in the notification. The separate notification relating to maize did not assist the assessee because it covered maize products in a different manner and did not exempt maize as such, nor the mixture in question.

Conclusion: The mixture did not fall within the scope of the exemption notification and was liable to tax.

Ratio Decidendi: An exemption notification must be construed strictly, and a commodity is exempt only if it falls squarely within the specific description used in the notification.

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