Tax exemption notification construed in taxpayer's favour: concessional duty extended to the extent duty-paid iron was used.

A taxing exemption notification must be construed reasonably and in favour of the taxpayer where its language is ambiguous, and words cannot be read in to restrict the concession beyond the text or object. On that approach, Notification No. 30/60 granted the concessional duty rate to the extent duty-paid iron was used in manufacturing steel ingots, not only where the ingots were made exclusively from duty-paid pig iron. The later clarification confirmed that the benefit was linked to the use of duty-paid iron in crude form, and a narrower reading would have defeated the intended relief and risked double duty on the same subject-matter.

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Issues: Whether Notification No. 30/60 dated 1st March 1960 granted the concessional rate of duty only to steel ingots manufactured exclusively out of duty-paid pig iron, or whether the concession extended proportionately to the extent duty-paid iron was used in the manufacture of steel ingots.

Analysis: The notification was construed in light of its language, object, and the subsequent Notification No. G.S.R. 610 dated 30th March 1968, which clarified that the concession was linked to the use of duty-paid iron in crude form. The addition of the word "only" by the revenue authorities found no support in the text of the 1960 notification. A construction confining the benefit to steel ingots manufactured exclusively from duty-paid pig iron would make the notification ineffective in practice and defeat the intended relief. As the notification imposed a fiscal burden, any reasonable doubt had to be resolved in favour of the taxpayer, and the language could not be strained to impose duty twice on the same subject-matter.

Conclusion: The notification applied to the extent duty-paid iron was used in the manufacture of steel ingots, and not merely where the ingots were made exclusively from duty-paid pig iron.

Ratio Decidendi: A taxing exemption notification must be construed reasonably and in favour of the subject where its language is ambiguous, and words cannot be read into it to restrict a concession beyond what its text and object support.

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