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Issues: Whether the petitioner's ruled and unruled student exercise notebooks were covered by the exemption granted under G.O.Ms. No. 79 dated 23.03.2007 and the relevant schedule entries under the Tamil Nadu Value Added Tax Act, 2007.
Analysis: The exemption and schedule entries distinguished between graph books, exercise books, laboratory notebooks, student notebooks and copy books. The petitioner clarified in its objections that it manufactured only standard ruled and unruled exercise notebooks. No material was produced to dislodge that clarification. On the plain wording of the Government Order and the schedule entries, notebooks used by students for academic exercises fell within the exempted category of exercise notebooks. A taxing entry must be applied according to its language, and a restrictive construction excluding such notebooks was not justified on the facts found.
Conclusion: The denial of exemption was unsustainable and the petitioner was entitled to the benefit of G.O.Ms. No. 79 dated 23.03.2007.
Ratio Decidendi: Where the assessee establishes that its goods squarely answer the exempted commodity description in the notification or schedule entry, the exemption must be given effect according to the plain wording of the provision.