Exemption notification scope upheld where delegated power allowed the Government to limit relief to specified goods.

The State's delegated power to issue an exemption notification under the Tamil Nadu General Sales Tax Act allowed it to confine relief to specified classes of goods, including raw materials, packing materials and consumables. The expression "any goods" in Section 4-E did not require exemption to extend to every item, especially where plant and machinery were statutorily excluded. In writ jurisdiction, the court could test only whether the notification was within the statutory framework; it could not compel the Government to enlarge the exemption or frame the notification in a different form. The notification was therefore upheld as not ultra vires Section 4-E.

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Issues: Whether the exemption notification restricting relief to raw materials, packing materials and consumable goods was ultra vires Section 4-E of the Tamil Nadu General Sales Tax Act, 1959 and liable to be struck down in writ jurisdiction.

Analysis: The impugned notification was issued in exercise of the State Government's delegated legislative power under Section 17(1) of the Tamil Nadu General Sales Tax Act, 1959. The power to grant exemption includes the power to determine the class or category of goods to which exemption is confined. The expression "any goods" in Section 4-E was treated as subject to the statutory exclusion of plant and machinery, and it did not compel the Government to extend exemption to every conceivable item. The Court held that it could examine only the validity of the notification and whether it was in consonance with law, but it could not direct the Government to frame the notification in a particular manner or enlarge the scope of exemption, as that would amount to interference with a legislative function.

Conclusion: The notification was not ultra vires Section 4-E, and the challenge failed.

Ratio Decidendi: A court cannot, in exercise of writ jurisdiction, compel the State Government to expand the scope of an exemption notification issued under delegated legislative power, so long as the notification remains within the statutory framework.

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