Strict construction of tax concessions denies set-off where manufacture was not by the expressly specified class of rerollers.

A sales tax set-off under G.O. Ms. No. 774 dated 9 July 1985 was confined to finished products manufactured in the State from rerollable scrap by steel rerollers and mini steel plant-cum-rerollers. A dealer who did not own such a unit, but got the scrap converted through hired rerollers, satisfied the local purchase, manufacture and sale conditions yet failed the express requirement that the manufacture be by the specified class of assessees. Earlier authorities on different statutory language, such as "manufacturer" or "miller," did not justify extending the concession. In exemption matters, ambiguity is resolved against the claimant, so the dealer was not entitled to the set-off.

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Issues: Whether the dealer, who did not own a reroller or mini steel plant-cum-reroller but got rerollable scrap converted into finished products through hired rerollers, was entitled to the sales tax set-off under G.O. Ms. No. 774 dated 9 July 1985.

Analysis: The Government Order granted set-off in respect of finished products manufactured within the State from rerollable scrap purchased within the State, but its language expressly confined the benefit to manufacture by steel rerollers and mini steel plant-cum-rerollers. The dealer satisfied the conditions relating to local purchase, local manufacture, and local sale, but failed on the condition that the manufacture be by the specified category of assessees. The earlier decisions relied upon concerned different statutory expressions such as "manufacturer" or "miller" and did not support extending the concession to a dealer who merely arranged manufacture through hired rerollers. In exemption matters, any doubt must be resolved against the claimant and in favour of the State.

Conclusion: The dealer was not entitled to the set-off under the Government Order, and the claim failed.

Final Conclusion: The revision was held to be without merit because the concession was confined to the class expressly named in the Government Order and could not be extended by interpretation to the dealer.

Ratio Decidendi: A tax concession or set-off notification must be strictly construed, and the benefit cannot be extended beyond the class of persons expressly covered by its language.

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