Exemption notifications must be read strictly; Commission sales were outside the notified class and not tax exempt.

Exemption notifications under the sales tax enactments were construed according to their plain language and confined to sales of specified village industry products made by institutions or persons certified by the Khadi & Village Industries Commission or the State Board. The Commission itself was not a certified institution or person, so its onward sales did not fall within the notified class of exempt transactions. The Commission therefore could not claim exemption for those sales, and the benefit of the notification remained limited to sales by the expressly covered certified manufacturers.

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Issues: Whether the sales effected by the Khadi & Village Industries Commission were exempt under the notifications issued under the sales tax enactments.

Analysis: The exemption notifications, on their plain language, covered sales of specified village industry products effected by institutions and persons certified by the Khadi & Village Industries Commission or the State Board. The Commission itself was not a certified institution or person. The notifications therefore applied to the sales made by the certified manufacturers, not to the Commission's onward sales to others.

Conclusion: The Commission could not claim exemption under the notifications for its sales, and the issue was decided against the assessee.

Final Conclusion: The decision confined the exemption to sales by certified institutions and persons and rejected the Commission's claim for exemption on its onward sales.

Ratio Decidendi: An exemption notification must be applied according to its clear language, and its benefit cannot be extended to a person or transaction not expressly covered by the notification.

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