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Issues: Whether the exemption entry for "Hank Yarn" in the Fourth Schedule to the Tamil Nadu Value Added Tax Act, 2006 was confined only to cotton hank yarn or to hank yarn generally, and whether external aids such as the Budget speech could be used to restrict the plain wording of the entry.
Analysis: The entry used the unqualified expression "Hank Yarn" and was held to be clear, direct, and unambiguous. On that construction, there was no basis to confine the exemption to cotton hank yarn or to limit it by reference to the user industry. The Budget speech did not expressly restrict the exemption to cotton hank yarn, and external aids of interpretation could not be invoked to create ambiguity where none existed. The reliance placed on the decision concerning Section 52(2) of the Income-tax Act, 1961 was found inapposite because the present entry required no departure from its plain language.
Conclusion: The exemption under Entry 44 was held to extend to hank yarn generally and not merely to cotton hank yarn; the challenge to that view was rejected.
Final Conclusion: The special leave petition was declined, leaving the High Court's interpretation of the exemption entry undisturbed.
Ratio Decidendi: Where the language of an exemption entry is clear and unqualified, it must be applied according to its plain meaning and cannot be narrowed by external aids or inferred legislative intent.