Strict construction of tax concession rules bars manufacturer registration without exclusive control of the manufacturing unit.

A dealer seeking concessional purchase tax under section 5-B of the A.P. General Sales Tax Act must satisfy the strict condition of having his own manufacturing unit or a unit under his exclusive control within the State, and the registration scheme still requires disclosure of the manufacturing concern and place of manufacture. On the plain meaning of "having his manufacturing unit," a dealer who gets goods manufactured in a unit controlled by others does not qualify as a manufacturer. The dealers, lacking exclusive control over the biscuit-manufacturing units, failed the statutory requirement and could not claim the concessional rate of tax.

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Issues: Whether a dealer who does not own or exclusively control a manufacturing unit within the State can be registered as a manufacturer and claim the concessional rate of tax under section 5-B of the A.P. General Sales Tax Act, 1957.

Analysis: Section 5-B, as amended, conditions the concessional levy on purchases of raw materials by a dealer who intends to manufacture goods inside the State and, in context, contemplates a dealer having his own manufacturing unit or a unit under his exclusive control. The earlier definition of "manufacturer" in rule 3(gg) was deleted, and the amended rule 30-A and rule 30-B introduced a registration mechanism that still required disclosure of the manufacturing concern and the place of manufacture. The Court held that the cited decisions on the meaning of "manufacturer" in different statutory contexts did not assist the petitioners, because the decisive expression here was "having his manufacturing unit". On a plain reading, that phrase excludes a dealer who gets goods manufactured in a unit over which others also have control. As the petitioners had no exclusive control over the units where biscuits were manufactured, they failed to satisfy the statutory condition. Being a provision granting a tax concession, section 5-B had to be construed strictly, and no wider meaning could be read into it.

Conclusion: A dealer without his own or exclusively controlled manufacturing unit is not entitled to registration as a manufacturer under section 5-B, and the claim for concessional tax fails.

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