Exemption certificates confined to manufacture and sale do not imply purchase tax relief absent express coverage.

An exemption certificate under an industrial incentive scheme was confined to goods manufactured and sold, and did not extend by implication to purchase tax on rubber wood used in manufacture. The governing notification and the true scope of the District Industries Centre certificate controlled the claim, and the goods were also not taxable at the last purchase point. Applying the principle from the Supreme Court on construing similar exemption notifications, the Kerala HC treated the cited authorities on interference with exemption certificates as distinguishable because no purchase-tax relief had ever been granted. The assessee's claim therefore failed, and the reassessment and appellate orders were upheld.

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Issues: Whether the assessee was entitled to exemption from purchase tax on rubber wood used for manufacture, in light of the exemption certificate and the governing notification, and whether the reassessment and appellate orders denying such exemption were liable to be interfered with.

Analysis: The exemption was claimed under the industrial incentive scheme, but the controversy turned on the true scope of the certificate issued by the District Industries Centre. The certificate expressly covered exemption on goods manufactured and sold, and did not grant exemption from purchase tax. The relevant goods were also not taxable at the last purchase point. In these circumstances, the principle applied in the Supreme Court decision on the meaning of a similar exemption notification governed the case. The authorities relied upon by the assessee on interference with an exemption certificate were distinguishable because those cases concerned an attempt by a lower authority to dilute a benefit actually granted by a superior authority, whereas here no purchase tax exemption had been granted at all.

Conclusion: The assessee was not entitled to exemption from purchase tax, and the reassessment and appellate orders denying the claim were upheld.

Ratio Decidendi: An exemption certificate or notification granting relief on manufacture and sale does not, by implication, extend to purchase tax where the certificate does not expressly grant such relief and the goods are not taxable at the last purchase point.

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