Exemption in taxing statutes cannot be expanded by implication; charitable education institutions remained liable to electricity duty.

Under the Maharashtra Electricity Duty Act, 2016, charitable education institutions were excluded from electricity duty exemption because the new scheme retained relief only for the categories expressly named in the provision. The omission of the earlier charitable-institution clause was treated as deliberate, and the exemption could not be expanded by implication, legislative intention, or continuity from the repealed law. The Court also rejected reliance on Article 14 and the doctrine of last antecedent, holding that the exemption text was plain and unambiguous and could not be enlarged to cover omitted beneficiaries. The levy of electricity duty on such institutions was therefore upheld.

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Issues: (i) Whether charitable education institutions remained exempt from electricity duty after the Maharashtra Electricity Duty Act, 2016 came into force. (ii) Whether the words of the exemption provision could be read to extend to charitable institutions on the basis of legislative intention, Article 14, or the doctrine of last antecedent.

Issue (i): Whether charitable education institutions remained exempt from electricity duty after the Maharashtra Electricity Duty Act, 2016 came into force.

Analysis: The exemption under the earlier regime specifically covered charitable institutions running schools or colleges. The later enactment restructured the charging and exemption scheme and expressly retained exemption only for the categories stated in the new provision, namely educational and allied uses by local bodies, apart from the State Government, the Central Government, and other specifically identified categories. The omission of the earlier charitable-institution clause was treated as deliberate. In a taxing statute, an exemption must be found within the clear language of the provision and cannot be expanded by implication or by resort to presumed continuity with the repealed law.

Conclusion: The charitable education institutions were not entitled to exemption from electricity duty under the 2016 Act.

Issue (ii): Whether the words of the exemption provision could be read to extend to charitable institutions on the basis of legislative intention, Article 14, or the doctrine of last antecedent.

Analysis: The Court held that the language of the exemption clause was plain and unambiguous and that recourse to purposive construction was not permitted to add a category not included by the legislature. Acceptance of the broader reading urged for the institutions would distort the text and extend the exemption beyond its stated scope. The argument based on Article 14 failed because the provision, as enacted, did not create a constitutionally impermissible classification on the footing urged. The doctrine of last antecedent was also found inapplicable because the provision did not leave the relevant words ambiguous on the scope of the exempted entities.

Conclusion: The provision could not be enlarged by interpretive devices, and the challenge based on Article 14 and last antecedent was rejected.

Final Conclusion: The exemption available under the earlier law did not survive for charitable education institutions under the 2016 statutory scheme, and the levy of electricity duty on such institutions was upheld.

Ratio Decidendi: In an exemption provision under a taxing statute, only those beneficiaries clearly brought within the plain language of the enactment can claim the benefit, and a court cannot add omitted categories by implication, purposive reading, or interpretive presumption.

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