Concessional sales tax notifications must be read strictly: gold bullion relief did not extend to silver bullion.

A concessional sales tax notification must be construed by its clear language, and a concession expressed for bullion and specie with the word "gold" was held to cover only gold bullion and specie. Silver bullion could not be brought within the reduced rate by interpretation, and the later omission of the word "gold" in a subsequent notification did not operate retrospectively to expand the earlier concession. The contemporaneous administrative clarification was also treated as supporting the restricted reading, with no ambiguity found to justify a liberal construction in favour of the assessee. The reassessment taxing silver bullion at the normal rate was sustained.

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Issues: Whether the reduced rate of sales tax under the relevant Government Orders issued under section 9(1) of the Andhra Pradesh General Sales Tax Act, 1957 applied to silver bullion.

Analysis: The entry in the First Schedule covered bullion and specie, while the explanatory material showed that bullion meant pure gold or silver in mass form. The Government Orders, however, reduced tax on bullion and specie (gold), and the Court read the bracketed word "gold" as qualifying the concessional entry as a whole. On that construction, the concession was confined to gold bullion and specie and did not extend to silver bullion. The later omission of the word "gold" in a subsequent notification did not enlarge the earlier concession retrospectively. The Court also relied on the contemporaneous clarification issued by the Commercial Taxes authorities and held that there was no ambiguity warranting a liberal interpretation in favour of the assessee.

Conclusion: The reduced rate of sales tax was not available to silver bullion; the reassessment bringing the turnover to tax at the normal rate was sustained.

Ratio Decidendi: A concessional sales tax notification must be construed according to its clear language, and where the concession is expressly confined to gold bullion and specie, it cannot be extended by interpretation to silver bullion.

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