Broad construction of "paper and pulp" covers strawboard for industrial tax incentives and related reliefs.

Strawboard was treated as falling within the expression "paper and pulp" in the relevant tax schedules, because that phrase was construed broadly to cover the paper and pulp industry as a whole. The Court relied on the comparable manufacturing process, the industrial licence, and the statutory treatment of strawboard alongside paperboard and newsprint to support inclusion. A liberal interpretation was applied to advance the purpose of tax incentives for industrial development, with the result that the assessee qualified for concessional income-tax treatment, higher development rebate, and deduction under section 80E.

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Issues: Whether strawboard falls within the expression "paper and pulp" in the relevant tax schedules so as to entitle the assessee to concessional rates of income-tax, development rebate at the higher rate, and deduction under section 80E.

Analysis: The relevant schedules were intended to encourage industrial activity and the expression "paper and pulp" was held to denote the paper and pulp industry in a comprehensive sense. The manufacturing process of strawboard was treated as identical to that of paper, and the material before the Court, including the industrial licence and the statutory treatment of strawboard with paperboard and newsprint, supported inclusion of strawboard within that industrial category. A liberal construction was applied because the provision granted tax incentives for industrial development.

Conclusion: Strawboard was covered by "paper and pulp" and the assessee was entitled to the claimed reliefs; the appeals were dismissed.

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