Liberal construction of exemption notifications brought brass intermediate goods within "parts thereof" and secured sales tax relief.

An exemption notification for brassware was construed liberally to give effect to its beneficial object of encouraging the industry. Gullis and sillis made by karkhanedars from brass scrap were treated as intermediate articles integral to the manufacture of utensils, and therefore as "parts thereof" within the notification. The Court rejected the Revenue's narrower reading based on circulars and applied the ordinary meaning of the terms in a purposive manner. On that construction, the assessees fell within the exemption from sales tax.

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Issues: Whether gullis and sillis manufactured by karkhanedars from brass scrap are covered by the exemption notifications as "utensils or parts thereof" and therefore entitled to exemption from sales tax.

Analysis: The exemption notifications applied to karkhanedars manufacturing their own utensils or art brasswares from their own raw materials and selling them without polishing, buffing, engraving or colouring. The Court examined the ordinary meaning of "utensil" and "part", and held that gullis and sillis, though intermediate products made from brass scrap, constitute material from which utensils are ultimately manufactured and are integral to that manufacturing process. The Court further held that the object of the notifications was to encourage the brassware industry, so the expressions used in them had to receive a liberal and purposive construction rather than a narrow literal one. The circular and authorities cited by the Revenue did not displace this construction.

Conclusion: Gullis and sillis manufactured by karkhanedars were held to be parts of utensils within the meaning of the exemption notifications, and the assessees were entitled to exemption.

Ratio Decidendi: Where an exemption notification for a beneficial fiscal scheme uses the expression "parts thereof", the expression must be construed liberally in light of the object of the notification, and intermediate articles integral to the manufacture of the exempted goods may fall within that expression.

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