Reading books exemption applies to alphabet charts sold by a printer when the printed material is educational reading matter.

Alphabet charts sold by a printer were held to be "books" or "reading books" within the exemption for reading books, including text books, because their essential character was educational reading material used to teach children the alphabet. The fact that the seller was a printer did not change the character of the goods where the printed articles themselves were exempt books. The Court also noted that even if the transaction involved a deemed sale in a printing contract, the exemption would still apply if the underlying goods were exempt printed books. The revisional order was unsustainable and the exemption was restored.

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Issues: (i) Whether alphabet charts sold by a printer are "books" or "reading books" within the exempted entry for reading books including text books under the Tamil Nadu General Sales Tax Act, 1959. (ii) Whether exemption available to sale of reading books including text books extends to a printer who prints and sells such alphabet charts.

Analysis: The expression "reading books" was construed broadly as "books for reading" rather than by reference to physical form alone. Alphabet charts were treated as basic reading material used to teach children the alphabet and as an elementary text for literacy. Prior clarifications issued by the department also recognized similar printed learning materials, including alphabet charts, as exempt reading books. The fact that the assessee was a printer did not alter the character of the goods when the printed articles themselves were books meant for reading. The Court further noted that where the printer supplies materials in a contract, the transaction may involve deemed sale under the constitutional concept of sale in article 366(29-A), but the same exemption would apply if the underlying goods are exempt printed books.

Conclusion: The alphabet charts were books or reading books and the printer selling them was entitled to the exemption. The issue was decided in favour of the assessee.

Final Conclusion: The revisional order was unsustainable and the appellate order granting exemption was restored, resulting in success for the assessee.

Ratio Decidendi: An educational printed item may qualify as a "reading book" for exemption if its essential character is that of reading material, and the printer who sells such exempt goods is not denied the exemption merely because of his capacity as printer.

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