Strict construction of exemption notifications denies firewood tax relief when sold as paper-making raw material rather than fuel.

Firewood sold to a paper mill for use as raw material in manufacturing paper was held not to qualify for sales tax exemption where the notification covered firewood only when used as firewood or fuel. The note states that an exemption entry must be construed strictly, and the claimant must clearly show that the goods fall within the exempted category. Because the firewood was diverted to another industrial use, the exemption was not available. Any ambiguity in the notification was resolved in favour of the Revenue, so the claim to exemption failed.

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Issues: Whether firewood sold to a paper mill for use as raw material in manufacturing paper was entitled to exemption from sales tax under the exemption notification.

Analysis: The firewood was found to have been supplied for use as raw material in the manufacture of paper and not as fuel. The exemption entry for firewood was intended for firewood used as firewood, and not for wood diverted to another industrial use. Exemption notifications must be construed strictly, and the assessee claiming exemption must clearly show that the goods fall within the exempted category. Where there is ambiguity, the benefit does not go to the assessee but to the Revenue.

Conclusion: The claim to exemption was not sustainable, and the revision failed.

Ratio Decidendi: An exemption for firewood applies only when the firewood is intended to be used as firewood or fuel; if it is sold for another specified industrial purpose, the exemption cannot be extended, and any ambiguity in the exemption notification must be resolved in favour of the Revenue.

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