Purposive construction of artificial limb exemption extends to orthotics, prosthetics and rehabilitation aids used to restore function.

Orthotics, prosthetics and rehabilitation aids used to make a limb functional were covered by the sales tax exemption for artificial limbs under the Karnataka Sales Tax Act notification. The Court rejected a narrow dictionary-based reading, holding that the object of the exemption required a purposive construction and that appliances fitted to a limb formed part of the artificial limb concept. On that basis, the assessment orders were unsustainable to the extent they treated such devices as taxable.

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Issues: Whether orthotics, prosthetics and rehabilitation aids fell within the exemption granted for artificial limbs under the sales tax notification issued under section 8A of the Karnataka Sales Tax Act.

Analysis: The notification exempted tax on artificial limbs. The authorities had adopted a narrow dictionary-based approach and treated orthotics and rehabilitation aids as outside the expression. The Court held that the object of the notification had to be given effect and that appliances fitted to a limb, making a useless or minimally useful limb functional, were not to be excluded merely because they were not described in restrictive medical terminology. On that understanding, the fitment itself formed part of the artificial limb concept covered by the exemption.

Conclusion: Orthotics, prosthetics and rehabilitation aids used for making the limb useful were covered by the exemption and the assessment orders were unsustainable to that extent.

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