Plain meaning controls exemption scope: "Hank Yarn" covers all yarns in hank form, and contrary clarifications fail.

The clear and unqualified expression "Hank Yarn" in Entry 44 of Part B of the Fourth Schedule to the Tamil Nadu VAT Act was held to cover all yarns in hank form, not merely cotton hank yarn or yarn used by handloom units. The Court applied the plain meaning of the exemption entry and ruled that extraneous materials, including a Budget Speech, could not be used to read in a restriction absent from the text. It further held that departmental clarifications under Section 48-A could not override the statutory exemption. The clarifications dated 14.02.2013 and 29.06.2017 were therefore quashed.

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Issues: Whether the expression "Hank Yarn" in Entry 44 of Part B of the Fourth Schedule to the Tamil Nadu Value Added Tax Act, 2006 covers all yarns in hank form or only cotton hank yarn, and whether the departmental clarifications denying exemption were valid.

Analysis: Entry 44 used the unqualified expression "Hank Yarn", while Entry 3(a) of Part B of the First Schedule taxed all types of yarn other than those specified in the Fourth Schedule. The language of the exemption entry was clear and did not contain any restriction confining the exemption to cotton hank yarn or to yarn used only by handloom units. The Court held that where the statutory words are plain, no external aid such as a Budget Speech can be used to insert a limitation not found in the text. It further held that the departmental clarifications under Section 48-A could not override the plain scope of the exemption entry, and that no ambiguity or absurdity existed requiring a restrictive construction.

Conclusion: The exemption under Entry 44 applies to hank yarn of all varieties, including VSF and polyester yarn in hank form. The clarifications dated 14.02.2013 and 29.06.2017 were unsustainable and were quashed.

Ratio Decidendi: Where an exemption entry in a taxing statute is clear and unqualified, its scope cannot be narrowed by reference to extraneous materials or departmental intention, and the Court must give effect to the words used without adding limitations not expressed by the legislature.

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