Broader meaning of "paper" under entry 16B extended exemption to paper boards, pulp boards and duplex boards.

Paper boards, pulp boards and duplex boards were treated as falling within the broader statutory expression "paper" in Explanation II to entry 16B, because the legislative scheme and later amendments showed that paper was used as a genus covering such boards unless specifically excluded. The narrower common-parlance view limiting paper to writing paper was rejected in favour of a context-driven interpretation. On that construction, the items brought into the local area were within the exemption and not taxable under the entry, so the assessee was entitled to relief.

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Issues: Whether paper boards, pulp boards and duplex boards brought into the local area by the assessee were covered by the expression "paper" in Explanation II to entry 16B of the Schedule to the Karnataka Tax on Entry of Goods into Local Areas for Consumption, Use or Sale Therein Act, 1979, and were therefore exempt from tax.

Analysis: The expression "paper" in Explanation II was construed in the light of the legislative history of the entry and the later statutory treatment of paper as a genus covering all kinds of paper unless specific exclusions were made. The later amendment expressly excluded items such as pulp boards, duplex boards and other specified boards, showing that the statutory scheme treated such items as falling within the broader class of paper unless excluded. The narrow view that paper meant only writing paper was rejected, since the term was not to be confined to that limited common parlance meaning where the legislative context indicated a wider classification.

Conclusion: Paper boards, pulp boards and duplex boards were held to be covered by the expression "paper" in Explanation II to entry 16B and were not taxable under the entry. The assessee succeeded.

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