Strict construction of exemption notifications excludes gol papad from papad sales tax relief under commercial parlance test.

An exemption notification using the term "papad" was construed on its plain wording and in ordinary commercial parlance. The HC held that exemption entries must be read strictly, and a product cannot be extended benefit merely because it is made from similar ingredients or resembles the exempted article. On that approach, "papad" and "gol papad" were treated as distinct commercial commodities, and the notification's wording did not cover all papad-like products. The result was that gol papad did not fall within the sales tax exemption.

---

---

Issues: Whether "gol papad" manufactured from maida, rice, potato, sago and similar ingredients falls within the exemption for "papad" under the sales tax notification.

Analysis: The exemption notification issued under section 4(2) of the Rajasthan Sales Tax Act, 1954 used the word "papad" without any qualifying expression extending it to all varieties of papads. The Court applied the principle that exemption entries must be construed on the words employed, while the commodity must also be understood in ordinary commercial parlance as sold and purchased in the market. On that approach, "papad" and "gol papad" were treated as different commercial commodities, and the absence of any broader wording in the notification showed that the exemption was limited to papad as commonly understood, not to all papad-like products.

Conclusion: "Gol papad" is not exempt from sales tax under the notification.

Ratio Decidendi: An exemption notification must be interpreted according to its plain words in commercial parlance, and a commodity not covered by the wording cannot be brought within the exemption merely because it is made from similar raw materials or resembles the exempted article.

---