Strict construction of exemption notifications bars extending sales tax concession to purchase tax claims.

An industrial policy and exemption notification granting sales tax concession were construed strictly and held not to extend to purchase tax on raw coffee seeds. The repeated limitation of the concession to sales tax was treated as controlling, and the broader definition of tax could not be used to enlarge the exemption beyond its expressed subject-matter. The Court held that a clear exemption must be read as framed, without adding words or relying on authorities dealing with the sale and purchase aspects of a transaction in a different context. The assessee's claim for purchase tax relief was therefore rejected.

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Issues: Whether the industrial policy and the notification granting sales tax concession extended the benefit to purchase tax on raw coffee seeds.

Analysis: The policy clause and the statutory notification both used clear and repeated language confining the concession to sales tax. The mere definition of tax as including different levies did not justify treating purchase tax as part of sales tax. Where the language of an exemption is clear, the Court cannot enlarge it by interpretation or add words to extend the benefit beyond the stated subject-matter. The authorities cited on the nature of sale and purchase as two aspects of the same transaction were distinguished, because they did not deal with an industrial policy or an exemption notification framed in specific terms. The exemption notification had to be read as it stood, and the claim had to fall strictly within its four corners.

Conclusion: The concession did not extend to purchase tax, and the claim of the assessee was rejected.

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