Concessional tax notifications must be read strictly; benefit for one local body cannot be extended retrospectively to another.

A concessional-tax notification must be construed strictly by its express terms, and a benefit granted to one specified class cannot be extended by interpretation to another class not covered by the text. The 1996 notification applied only to zilla panchayats, while the later 1999 notification for taluk and gram panchayats operated prospectively and could not be treated as a retrospective clarification. As a result, supplies made to taluk panchayats before the later notification did not qualify for the concession, and the revisional authority's restoration of the assessment was upheld.

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Issues: Whether the concessional rate of tax granted by the 1996 notification to zilla panchayats could be extended retrospectively to supplies made to taluk panchayats, and whether the revisional authority was justified in restoring the assessment order.

Analysis: Section 8A of the Karnataka Sales Tax Act empowers the State Government to grant exemption or reduction in tax to a specified class of persons and to impose restrictions and conditions through the notification itself. The 1996 notification extended the concession only to zilla panchayats, while the 1999 notification for taluk panchayats and gram panchayats was issued separately and operated prospectively. A concession notified for one specified class cannot be enlarged by interpretation to cover another class not mentioned in the earlier notification. The later notification could not be treated as a clarification with retrospective effect, and the assessee could not claim the benefit for transactions made before its issuance.

Conclusion: The concessional rate under the 1996 notification was not available to supplies made to taluk panchayats, and the revisional order restoring the assessment was upheld.

Ratio Decidendi: An exemption or concessional-tax notification must be construed according to its express terms, and a benefit granted to a specified class cannot be extended retrospectively to a different class unless the notification clearly so provides.

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