Strict construction of exemption conditions denied relief where dealer also traded in goods beyond country oil chekku products.

An exemption confined to dealers owning or having interest in country oil chekku and dealing exclusively in its products must be strictly construed. The term "exclusively" was applied narrowly, and the assessee had to affirmatively prove full compliance with the exemption conditions. Inspection materials and the assessee's own statement showed dealings in paddy, rice, groundnut kernels, cane jaggery and other oils, so the statutory condition was not met. The exemption was therefore unavailable.

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Issues: Whether the assessee was entitled to exemption under G.O. Ms. No. 1963, Revenue, dated 21.04.1960, which applied only to a dealer owning or having interest in country oil chekku and dealing exclusively in the products of such chekkus.

Analysis: The exemption was confined to sales of products of country oil chekku by a person dealing exclusively in such products, and the expression "exclusively" had to be construed strictly. The materials from the inspection and the assessee's own statement showed dealings not only in country oil chekku products but also in paddy, rice, groundnut kernels, cane jaggery and other oils. The burden of proving entitlement to exemption was on the assessee, and that burden was not discharged.

Conclusion: The assessee was not entitled to the exemption.

Ratio Decidendi: An exemption confined to dealers dealing exclusively in specified products must be strictly construed, and the claimant must affirmatively prove full satisfaction of the exemption conditions.

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