Intra-ocular lens tax exemption treated as general, with no direct-sale condition and CST relief extended accordingly.

Intra-ocular lenses were treated as exempt goods under the Tamil Nadu General Sales Tax Act because they were specifically notified in the Third Schedule as aids for physically disadvantaged persons. The text rejects any implied condition that the exemption applied only when the lenses were sold directly to the end user, because no such restriction appeared in the statutory language. On that basis, the same exemption was extended to inter-State sales under the Central Sales Tax Act. The discussion frames the exemption as part of medical welfare policy and concludes that sales tax on intra-ocular lenses was not sustainable.

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Issues: Whether intra-ocular lenses were exempt from tax under the State sales tax law and the Central Sales Tax law, and whether the exemption could be treated as conditional only when the goods were sold directly to physically disadvantaged persons.

Analysis: The exemption provision in the Third Schedule to the Tamil Nadu General Sales Tax Act was read as a general exemption for the notified aids for physically disadvantaged persons. Intra-ocular lenses were specifically notified as exempt goods, and no express restriction or condition was found limiting the exemption to direct sales to the end user. The attempt to infer a conditional exemption was rejected as unsupported by the statutory text. Once the goods were treated as exempt under the State enactment, the same treatment extended to inter-State sales under the Central Sales Tax Act. The exemption was also viewed in the context of medical welfare and the constitutional obligation to ensure decent medical facilities.

Conclusion: The exemption was held to be general and not conditional, and the levy of sales tax on intra-ocular lenses was set aside.

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