Plain-language tax exemption notifications must be read as written; assumed purpose cannot narrow an express exemption.

A clear and unambiguous tax exemption notification must be interpreted according to its plain words, without adding limitations or reading in an assumed purpose. The SC held that, in taxing matters, equitable considerations are irrelevant and courts cannot supply omissions or restrict express language by reference to supposed legislative intention. Applying that rule to the notification covering sale or purchase of wheat and wheat products by roller flour mills within the State, the Court found the revisional authority and the High Court had wrongly denied the exemption on a restrictive construction. The assessee was therefore entitled to the benefit of the notification, and the first appellate relief was restored.

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Issues: Whether the exemption notification covering sale or purchase of wheat and wheat products by roller flour mills within the State had to be construed according to its plain language, and whether the revisional authority and the High Court were justified in denying the exemption by importing the supposed object or intention behind the notification.

Analysis: The notification issued under Section 9(1) of the Andhra Pradesh General Sales Tax Act, 1957 was found to be clear and unambiguous. The Court held that where the language of a tax notification is plain, courts cannot add words, supply omissions, or limit its scope by reference to assumed intention or supposed purpose. In taxing matters, equitable considerations are irrelevant and the interpretation must remain confined to what is expressly stated. The revisional authority and the High Court erred in proceeding on presumed legislative intention and in restricting the exemption despite the unqualified wording of the notification.

Conclusion: The exemption applied to the assessee for the relevant period, and the contrary view taken by the revisional authority and the High Court was unsustainable.

Final Conclusion: The assessee was entitled to the benefit of the notification as written, and the assessment orders stood displaced by restoration of the first appellate relief.

Ratio Decidendi: A clear and unambiguous tax exemption notification must be interpreted according to its plain words, without importing assumed intention, purpose, or limitations not expressed in the text.

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