https://www.taxtmi.com/caselaws?id=159479 Sales tax exemption notifications must be strictly construed, and their language cannot be expanded to grant 90% concession separately for each of five years. Where the notification imposed a cumulative ceiling linked to gross fixed capital investment, the concession operated only to the extent of the qualifying investment actually made. Additional investment made later could generate further exemption only from the date of that investment, not retrospectively for earlier years. On that basis, the exemption certificate correctly reflected the later entitlement, and the penalty notice was not liable to be quashed. en-us Fri, 30 Mar 1990 00:00:00 +0530 Tue, 26 Nov 2013 12:37:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=159479 Sales tax exemption notifications must be strictly construed, and their language cannot be expanded to grant 90% concession separately for each of five years. Where the notification imposed a cumulative ceiling linked to gross fixed capital investment, the concession operated only to the extent of the qualifying investment actually made. Additional investment made later could generate further exemption only from the date of that investment, not retrospectively for earlier years. On that basis, the exemption certificate correctly reflected the later entitlement, and the penalty notice was not liable to be quashed. Case-Laws VAT and Sales Tax Fri, 30 Mar 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=159479