Strict construction of tax exemptions allows power-loom fabrics for third parties to qualify where the notification's wording is broad.

Cotton fabrics produced on power-looms owned by a co-operative society remained within the exemption notifications even when manufactured for a third party under a weaving arrangement. The Court applied the plain language of the taxing exemption and held that, because the notification did not restrict the benefit to fabrics produced for the society's own account, such a limitation could not be implied. The controlling principle was that exemption notifications in tax law must be construed strictly according to their words, and the benefit cannot be denied by adding words not expressed or necessarily implied. The assessee was therefore entitled to excise exemption for the relevant period.

---

---

Issues: Whether cotton fabrics produced on power-looms owned by a co-operative society, but manufactured for a third party under a weaving arrangement, were covered by the exemption notifications issued under the excise rules.

Analysis: The levy under the charging provision applied to excisable goods manufactured in India, but the exemption notifications granted relief to cotton fabrics produced on power-looms owned by a co-operative society, subject to specified conditions. The decisive question was whether the benefit was confined to goods produced by the society for itself or whether it extended to fabrics produced on such power-looms even if the work was done for another person. In taxing provisions and exemption notifications, the controlling rule is that the Court must give effect to the clear language used and cannot add words based on assumed legislative purpose. Where the notification did not require production for the society's own account, the benefit could not be denied by implying such a restriction.

Conclusion: The exemption notifications applied on their plain terms, and the assessee was entitled to exemption from excise duty for the relevant period.

Ratio Decidendi: An exemption notification in a taxing statute must be construed strictly according to its language, and the benefit cannot be denied by reading into it a limitation that is not expressed or necessarily implied.

---