Exemption from tax under a broad notification covers purchase tax as well as sales tax under the Act.

A notification exempting women entrepreneurs in the tiny sector "from tax" was read to cover both sales tax and purchase tax because the Act defined "tax" broadly as any tax or other levy leviable under it. Since sales tax and purchase tax were both taxes leviable under the Act, the exemption applied to purchases as well. The State's power to exempt fully or partly from tax on the sale or purchase of goods, or classes of persons, supported that reading. Reliance on the Chief Minister's speech could not narrow the plain language of the notification. The assessee was therefore not liable to pay purchase tax on the covered purchases.

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Issues: Whether the notification dated 7-3-1994 exempting women entrepreneurs in the tiny sector from tax covered purchase tax as well as sales tax.

Analysis: The notification used the expression "exempts from tax", and the Act defined "tax" broadly as any tax or other levy leviable under the Act. Sales tax was leviable under section 4 and purchase tax under section 11. Section 15 empowered the State Government to exempt fully or partially from tax the sale or purchase of any goods or class of goods or any person or class of persons. On a plain reading, the exemption therefore extended to all taxes leviable under the Act, including purchase tax. Reliance on the Chief Minister's speech could not restrict the natural meaning of the notification, since legislative speech cannot cut down clear statutory language.

Conclusion: The notification covered purchase tax also, and the assessee was not liable to pay purchase tax on the covered purchases.

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