Plain language controls exemption notifications where a proviso cannot deny textile sales tax relief unless its conditions are met.

An exemption notification in a taxing statute must be construed on its plain terms, and a proviso cannot narrow a broad exemption unless its conditions are expressly attracted. Here, the opening text granted a wide sales tax exemption for textiles, and the proviso was held to apply only where the goods were actually liable to additional excise duty under the central levy. Because the textile goods in the appellants' stock were not so liable, the proviso did not cut down the exemption. The stated object of avoiding double taxation could not override the clear language of the notification, so the textile goods remained exempt from sales tax.

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Issues: Whether the proviso to the sales tax exemption notification restricted the exemption so as to exclude textile goods not liable to additional excise duty under clause 3(1) of the Additional Duties of Excise Bill, 1957, and whether the appellants were entitled to exemption from sales tax on the textile goods in their stock on 14 December 1957.

Analysis: The opening paragraph of the notification granted a broad exemption for textiles. The proviso had to be read with its attached conditions and, on its proper construction, applied only where the goods were in fact liable to additional excise duty under the central levy. The phrase "any class of such goods" referred only to goods falling within the entire taxing provision so that duty was actually leviable. Since the appellants' textile goods were not liable to such excise duty, the proviso did not operate to cut down the exemption. The Court also held that the supposed object of avoiding double taxation could not override the clear words used in the notification.

Conclusion: The appellants were entitled to the benefit of the exemption notification and were not liable to sales tax on the relevant textile stock.

Final Conclusion: The appeal succeeded and the demand for sales tax on the specified textile goods could not be sustained.

Ratio Decidendi: An exemption notification in a taxing statute must be construed according to its plain terms, and a proviso cannot be used to deny the exemption unless its conditions are attracted on the express language of the provision.

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