Plain meaning of exemption entry excludes molasses-based ethyl alcohol manufacturers from the negative list under the incentive scheme.

In a sales tax exemption notification, the negative-list entry for industries based on ethanol or ethyl alcohol was construed according to its plain language. The Court treated the phrase "except non-molasses alcohol industries" as an exception limited to that main clause and held that "based on" refers to industries using ethyl alcohol as an input, not to units manufacturing it. On that reading, a unit manufacturing ethyl alcohol from molasses does not fall within the negative list. The exemption could not be denied on that ground, because a broader construction would make the word "based" redundant and extend the exception beyond its proper scope.

---

---

Issues: Whether a unit manufacturing ethyl alcohol from molasses falls within entry 10 of the negative list in the Haryana sales tax exemption notification, so as to be denied eligibility for exemption under the incentive scheme.

Analysis: The entry was held to contain one main clause, namely, industries based on ethanol or ethyl alcohol, with the words "except non-molasses alcohol industries" operating only as an exception to that main clause. The expression "based on" was treated as referring to industries using ethyl alcohol as an input, not to industries engaged in its manufacture. Applying the settled rule that exemption entries and their exceptions must be construed on their plain language, without intendment or assumptions, the Court held that the exception excludes only industries based on alcohol manufactured from non-molasses. A construction that treated manufacturers of ethyl alcohol from molasses as covered by the negative list would make the word "based" redundant and would expand the exception beyond its proper field.

Conclusion: A manufacturer of ethyl alcohol from molasses does not fall within entry 10 of the negative list and cannot be denied exemption on that ground.

Ratio Decidendi: In a taxing exemption notification, the operative words must be given their plain meaning, and an exception or proviso can operate only within the scope of the main clause; therefore, "ethanol (ethyl alcohol) based industries" does not include manufacturers of ethyl alcohol, and the exception "except non-molasses alcohol industries" excludes only industries based on alcohol manufactured from non-molasses.

---