Concessional tax on tyres could not survive supersession of the earlier notification for the intervening period.

The concessional tax rate on tyres under Notification S.R.O. No. 453/1983 did not continue after that notification was superseded by S.R.O. No. 1716/1987, which replaced the earlier concession and omitted tyres. In the context of exemption and concession notifications, supersession operates as cancellation and replacement from the date of the later notification, and the power to grant, vary, or cancel concessions is prospective. The later S.R.O. No. 362/1988 showed that the reduced rate for tyres applied only from 1 April 1988. Strict construction of concession notifications therefore prevented extension of the benefit to the intervening period, and the claim failed.

---

---

Issues: Whether the concessional rate of tax on the sale of tyres under Notification S.R.O. No. 453/1983 continued to apply for the period after its supersession by Notification S.R.O. No. 1716/1987 and before the later notification granting a concession from 1 April 1988.

Analysis: The reduction in tax on tyres was originally granted under Notification S.R.O. No. 453/1983. Notification S.R.O. No. 1716/1987 superseded that notification and confined the concession to specified items, omitting tyres. The effect of supersession in the context of exemption or concession notifications is cancellation and replacement from the date of the later notification, not continuation of omitted items. Section 10 of the Kerala General Sales Tax Act, 1963 empowered the Government to grant, vary, or cancel such notifications prospectively. The later Notification S.R.O. No. 362/1988 showed that the reduced rate on tyres was granted only from 1 April 1988. Since exemption or reduction notifications are to be strictly construed, no external aid could be used to extend the concession beyond the clear language of the later notification.

Conclusion: The assessee was not entitled to the concessional rate on tyres for the disputed period, and the claim failed.

---