Exemption notification for roller flour mills construed narrowly: only mills undertaking grinding activity could claim the concession.

An exemption notification under the Andhra Pradesh General Sales Tax Act was construed according to its object and the background of the representation that procured it. The concession was intended for roller flour mills purchasing wheat for grinding activity, so mills that merely bought and sold wheat without undertaking grinding did not fall within the beneficiary class. The earlier broad reading was treated as based on a misunderstanding of the notification, and a concession obtained by misrepresentation could not be expanded through promissory estoppel. The revisional order withdrawing the appellate relief was therefore upheld, and the exemption was denied to the appellants.

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Issues: Whether the exemption under G.O. Ms. No. 377 dated 2 May 1991, issued under the Andhra Pradesh General Sales Tax Act, 1957, applied to roller flour mills that did not undertake the grinding of wheat and wheat products, and whether the revisional order withdrawing the appellate relief was justified.

Analysis: The exemption notification was issued under section 9 of the Andhra Pradesh General Sales Tax Act, 1957, but its object had to be gathered from the background in which it was procured. The representation of the roller flour mills association sought relief for mills purchasing wheat for grinding in their mills, showing that the concession was linked to the grinding activity. The earlier view granting a general exemption was found to rest on a misunderstanding of the notification. The Court also relied on the earlier decision holding that the notification had been obtained by misrepresentation and that a concession procured in that manner could not be extended on the footing of promissory estoppel. The expression used in the notification could not be read divorced from its purpose, and a mill that merely bought and sold wheat without grinding did not answer the intended class of beneficiaries.

Conclusion: The exemption did not extend to the appellants, and the revisional order withdrawing the relief was upheld.

Final Conclusion: The appeals failed because the exemption was confined to roller flour mills undertaking grinding activity, and the appellants, not having undertaken that process, were not entitled to the benefit.

Ratio Decidendi: An exemption notification procured for a specific industrial activity must be construed according to its intended purpose, and a concession obtained by misrepresentation cannot be enlarged beyond the class of beneficiaries for whom it was granted.

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