2001 (1) TMI 952

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....bunal was delivered by L. PALAMALAI (Administrative Member).-This tax appeal case is against the order of the Joint Commissioner-III (SMR) of Commercial Taxes, Chennai, in Ref. No. N1/3584/91 dated April 7, 1994. The dispute relates to a turnover of Rs. 10,03,717 assessed to tax in the suo motu revision as sales of "Tapioca thippi flour" for the assessment year 1990-91 and for which, the assess....

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....[1983] 53 STC Statutes 6. †See [1993] 89 STC Circulars and Clarifications, page 4, Sl. No. 34. been clearly stated that the buyer received only "tapioca thippi flour" in terms of the purchase order. Referring to the purchase order and also the goods receipt notes available in the assessment file, the Joint Commissioner categorically stated that the assessee supplied only "tapioca thippi ....

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....ch was derived from "tapioca thippi" was held to be eligible for exemption, in terms of the Government Notification in G.O.P. No. 290/CTRE dated March 11, 1983. 5.. Mr. R. Mahadevan, Learned Government Advocate, contended that the Joint Commissioner has categorically stated, with reference to the materials available in the record that the assessee sold only "tapioca thippi flour" and that the e....

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....ion specifically refers to "tapioca thippi" only. While considering the exemption notification, it should be construed strictly and in that view, we find that there is no case to extend the exemption for "tapioca thippi flour". As rightly pointed out by the Joint Commissioner in his order with reference to purchase orders and goods receipt notes, it has been categorically shown that the assessee s....