Strict construction of tax exemptions limits relief to the specific levy named in the notification.

An exemption notification issued under section 8-A of the Karnataka Sales Tax Act was confined to tax payable under section 5 on specified goods and did not extend to turnover tax under section 6-B. The court applied strict construction of exemption provisions and held that the narrower phrase "tax payable under section 5" could not be enlarged by implication to cover another levy under the Act. Earlier authorities using broader wording such as "tax under the Act" were distinguished. The assessment levying turnover tax under section 6-B was therefore upheld.

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Issues: Whether the exemption notification issued under section 8-A of the Karnataka Sales Tax Act, 1957, exempting tax payable under section 5 on the sale of specified goods, also exempted turnover tax leviable under section 6-B of the Act.

Analysis: The notification expressly exempted only the tax payable under section 5. The expression "tax payable under section 5" could not, by any interpretative process, be extended to cover turnover tax under section 6-B. The general expression "tax payable under the Act" may include turnover tax, but the narrower wording used in the notification confined the exemption to section 5 alone. Exemption provisions in taxation laws are to be strictly construed, and their ambit cannot be enlarged by implication. The earlier decisions relied on were distinguished because they dealt with the wider expression "tax under the Act," not the narrower phrase used here.

Conclusion: The notification did not exempt turnover tax under section 6-B, and the assessment levying such tax was valid. The petition was rejected.

Ratio Decidendi: An exemption notification must be construed strictly, and where it exempts only tax payable under a specified section, the exemption cannot be extended to a different levy under another section unless the language clearly so provides.

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