Strict construction of tax exemptions bars extending a section 9 rate reduction to a separate section 9B levy.

Exemption notifications reducing tax on tea and loose tea under section 9 of the Madhya Pradesh Commercial Tax Act, 1994 did not extend to levy under section 9B. Section 9B creates a separate tax liability for dealers on resale of goods at the rate in Schedule II, and the notifications dated 9 May 1997 and 14 May 1997 expressly altered only section 9 without amending section 9B or Schedule II. Fiscal exemption notifications must be strictly construed, and no extension by implication is permitted. The reduced rate was therefore unavailable for dealers taxed under section 9B, and the claim to exemption failed.

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Issues: Whether the exemption notifications reducing the rate of tax under section 9 of the Madhya Pradesh Commercial Tax Act, 1994 for tea and loose tea also applied to levy of tax under section 9B of the Act.

Analysis: Section 9B creates a separate class of dealers liable to tax on resale of goods at the rate specified in column (3) of Schedule II. The notifications dated 9 May 1997 and 14 May 1997 expressly reduced the rate of tax under section 9 only and did not mention section 9B or amend Schedule II. Exemption notifications in fiscal statutes must be strictly construed, and nothing can be read into them by implication. Since the schedule rate was not altered and the notifications were confined to section 9, the reduced rate could not be extended to dealers governed by section 9B.

Conclusion: The benefit of the exemption notifications was not available for levy of tax under section 9B; the assessee's claim was rejected.

Ratio Decidendi: An exemption notification reducing tax for one charging provision cannot be extended to another distinct levy unless the notification or schedule expressly so provides; exemption clauses in fiscal statutes must be construed strictly.

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