Strict construction of tax exemptions excludes steam boilers from the category of scientific equipment for concessional rate purposes.

Exemption and concessional tax notifications must be strictly construed, and their benefit cannot extend beyond the express language used. An article qualifies as scientific equipment or instrument only if it is ordinarily understood in common parlance as relating to science by its character and use. A steam boiler, though scientifically manufactured and usable in a medical or educational setting, is also a common household article and is not identified in ordinary usage as scientific equipment. It therefore does not fall within the notification, and the concessional rate of tax is unavailable.

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Issues: Whether steam boilers sold to a medical college could be treated as "scientific equipment or instrument" within the meaning of the exemption notification so as to qualify for the concessional rate of tax.

Analysis: The notification granting concessional tax had to be construed strictly, and its benefit could not be extended beyond the express language used. In common parlance, a scientific instrument or equipment is one that applies scientific principles to common use. A steam boiler, though scientifically manufactured and used in a hospital or educational institution, does not by its character become scientific equipment or instrument, since it is also used as a household article and is not identified in common usage as an item relating to science.

Conclusion: Steam boilers do not fall within the expression "scientific equipment or instrument" in the notification, and the concessional rate was not available.

Ratio Decidendi: Exemption or concessional tax notifications must be strictly construed, and an article qualifies only if it is commonly understood as scientific equipment or instrument by reference to its ordinary character and use.

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