Madras High Court
M/S.Appasamy Associates vs The Commissioner Of Commercial ... on 15 July, 2021
W.P. Nos.4355 of 2008 etc., batch
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED : 15.07.2021
CORAM
THE HONOURABLE MR. JUSTICE S.M.SUBRAMANIAM
W.P.Nos.4355 of 2008, 36068 of 2004, 16051 of 2005,
4563, 5830, 5831, 8396 & 9011 of 2008,
21104 of 2009, 29013 to 29015 of 2011,
17 of 2014, 29404 of 2015, 22822 & 22823 of 2016, 762 & 763 of 2017,
3802, 11345 to 11347, 13428, 15964 & 16833 of 2018
and
W.P.(MD).Nos.4527 of 2009 & 5612 & 5613 of 2014
and
M.P.Nos.1 of 2008 (In 5 cases), 1 of 2009, 1 of 2011 (In 3 cases),
1 of 2014, 1 of 2015 & 2 of 2008
and
W.P.M.P.No.43397 of 2004 & W.V.M.P.No.340 of 2007
and
M.P.(MD) Nos.1 of 2009 & 1 of 2014 (In 2 cases)
W.P.No.4355 of 2007
M/s.Appasamy Associates,
Rep. By its Partner,
No.20, SBI Officers Colony,
First Street, Arumbakkam,
Chennai 600 106. .. Petitioner
-vs-
1.The Commissioner of Commercial Taxes,
Ezhilagam, Chepauk, Chennai 600 005.
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W.P. Nos.4355 of 2008 etc., batch
2.The Commercial Tax Officer,
Vadapalani-I Assessment Circle,
Chennai.
3.The Secretary to Government of Tamil Nadu,
Commercial Taxes and Registration Department,
Secretariat, Fort St. George, Chennai-9. .. Respondents
[R3 – Suo motu impleaded vide order
dated 06.07.2021 in W.P.No.4355 of 2009]
Writ Petition filed under Article 226 of the Constitution of India, to
issue a Writ of Certiorarified Mandamus, calling for the impugned
proceedings of the first respondent issued in Lr.No.K.Dis.Acts Cell
IV/58679/05 dated 02.05.2007 and quash the same and further direct the
respondents to grant exemption on the sales turnover of “Intra-ocular
lenses” both under the TNGST Act 1959 and CST Act 1956 as the above
goods are generally exempt from tax as goods falling under Item 2 of Part B
to the Third Schedule to the TNGST Act, 1959.
For Petitioner : Mr.P.Rajkumar
(In W.P.No.4355 of 2008 &
W.P.(MD) No.4527 of 2009)
For Petitioner : Mr.S.N.Kirubanandam
(In W.P.No.36068 of 2004)
For Petitioner : Ms.Lakshmi Sriram
(In W.P.Nos.16051 of 2005 & 9011 of 2008)
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W.P. Nos.4355 of 2008 etc., batch
For Petitioner : Mr.N.Inbarajan
(In W.P.No.4563 of 2008 & 21104 of 2009 &
W.P.(MD) Nos.5612 & 5613 of 2014)
For Petitioner : Mr.P.Rajkumar
(In W.P.Nos.5830, 5831, 8396 of 2008,
29013 to 29015 of 2011 & 17 of 2014)
For Petitioner : Mr.R.Senniappan
(In W.P.No.29404 of 2015)
For Petitioner : Mr.Hari Radhakrishnan
(In W.P.Nos.22822 & 22823 of 2016,
762 & 763 of 2017 & 3802 of 2018)
For Petitioner : Ms.R.Hemalatha
(In W.P.Nos.11345 to 11347, 13428,
15964 & 16833 of 2018)
For Respondent(s) : Mr.V.Nanmaran,
(In W.P.Nos.4355 of 2008, Government Advocate
36068 of 2004, 16051 of 2005, 4563, 5830,
5831 & 8396 of 2008, 21104 of 2009,
29013 to 29015 of 2011, 17 of 2014, 29404 of 2015,
22822 & 22823 of 2016, 762 & 763 of 2017, 3802,
11345 to 11347, 13428, 15964 & 16833 of 2018 and
W.P.(MD).Nos.4527 of 2009 & 5612 & 5613 of 2014)
For RR1 to 3 : Mr.V.Nanmaran,
(In W.P.No.9011 of 2008) Government Advocate
For R4 : No appearance
(In W.P.No.9011 of 2008)
********
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W.P. Nos.4355 of 2008 etc., batch
COMMON ORDER
All these writ petitions are filed by the petitioners/registered dealers
registered under the provisions of the Tamil Nadu General Sales Tax Act,
1959 (hereinafter referred to as “the TNGST Act”), Tamil Nadu Value
Added Tax Act, 2006 (hereinafter referred to as the “TNVAT Act”) and also
under the Central Sales Tax Act, 1956 (hereinafter referred to as “the CST
Act”). Admittedly, all the petitioners sell Intra-ocular lenses to wholesalers,
distributors, dealers and hospitals.
2.In view of the fact that the dispute and the issues raised in all these
writ petitions are common, the writ petitions are heard together and are
being disposed of by this common order and with the consent of the learned
counsels for the parties, W.P.No.4355 of 2008 is taken as the lead case.
3.The dispute in nutshell is as to whether the sale of Intra-ocular
lenses is exempted from tax under the provisions of the TNGST Act or not.
The facts in general are not in dispute between the parties. Thus, this Court
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is inclined to consider the provisions of the TNGST Act, in order to consider
the grounds raised.
4.The respective learned counsels appearing on behalf of the
petitioners mainly contended that there is a general exemption contemplated
in Item No.2 of Part-B of the Third Schedule to the TNGST Act in respect
of the Intra-ocular lenses. Item No.2 stipulates 'aids for physically
disadvantaged persons as notified by the Government'. The Government
issued Notification in G.O.No.30, dated 27th March, 2002 and in Serial
No.4, 'Intra-ocular lenses' are included. Thus, sale of Intra-ocular lenses is
exempted from sale tax and in violation of the general exemption granted
under the provisions of the TNGST Act, the respondents are demanding sale
tax from the petitioner/dealers. Thus, they are constrained to move the
present writ petitions.
5.To substantiate the said contentions, the learned counsels for the
petitioners reiterated that absolutely there is no conditional exemption and
therefore, the stand taken by the respondents is directly in contradiction
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with the exemption granted under the statute. The Commissioner of
Commercial Taxes, issued clarifications as early as in the year 2011 stating
that the sale of Intra-ocular lenses is generally exempted and therefore, the
subordinate authorities cannot impose sale tax on the sale of Intra-ocular
lenses. In spite of the clarifications issued by the Commissioner of
Commercial Taxes in the year 2011, many of the executives are demanding
sale tax and thus, the petitioners have approached this Court.
6.The petitioners solicited the attention of this Court with reference
to the exemption clause contemplated under Section 8 of the TNGST Act.
Section 8 enumerates that “subject to such restrictions and conditions as
may be prescribed, a dealer who deals in the goods specified in the Third
Schedule shall not be liable to pay any tax under the TNGST Act in respect
of such goods”.
7.It is contended that as contemplated under Section 8 of the
TNGST Act (exemption clause), there is no restriction or condition imposed
in the exemption granted in Item No.2 of Part-B of the Third Schedule to the
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TNGST Act. Thus, for all purposes, the exemptions are to be construed as
general exemptions and thus, the action initiated, contrary to the exemption,
is to be held as void.
8.As far as the CST Act is concerned, regarding sale of Intra-ocular
lenses inter-State, Section 8 of the CST Act contemplates “rates of tax on
sales in the course of inter-State trade or commerce”. Sub-section (1)
stipulates “every dealer, who in the course of inter-State trade or commerce,
sells to a registered dealer goods of the description referred to in sub-section
(3) shall be liable to pay tax under the CST Act, which shall be 3 percent, of
his turnover or at the rate applicable to the sale or purchase of such goods
inside the appropriate State under the Sales Tax law of that State, whichever
is lower”.
9.As per the above provision, the general exemption granted under
the State law is to be extended for the inter-State sales also. When Section 8
of the CST Act unambiguously contemplates that the exemption granted by
the State law is to be applied in respect of the inter-State sales falling under
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the CST Act, then there is no reason for imposition of sale tax, as far as the
sales of Intra-ocular lenses to the other States are concerned. In all respect,
the Intra-ocular lenses are exempted and the goods exempted cannot be
subjected to sale tax and thus, the actions taken are in violation of the
provisions of the Act.
10.The learned counsels for the petitioners are of the opinion that
there are many other exemptions wherein, certain restriction and conditions
are imposed. However, the exemptions regarding Intra-ocular lenses are
concerned, there is no such restrictions or conditions imposed and therefore,
it is to be construed as general exemption for the purpose of sale tax and
thus, the very contention raised by the respondents that it is a conditional
exemption has no basis nor supported with the provisions of the CST Act.
11.The learned Government Advocate appearing on behalf of the
respondents disputed the said contention stating that the exemption is
conditional because Item No.2 of Part-B of the Third Schedule to the
TNGST Act states “aids for physically disadvantaged persons as notified by
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W.P. Nos.4355 of 2008 etc., batch
the Government”. Admittedly, Government issued G.O.No.30, dated 27th
March, 2002 including Intra-ocular lenses under the exemption clause.
Therefore, if the Intra-ocular lenses are sold to physically disadvantaged
persons directly, then alone exemption would be applicable and not
otherwise. In other words, it is contended that Intra-ocular lenses sold by
the manufacturer to the dealer are not exempted and dealer to the hospital
are also not exempted and if the hospital is able to establish that such Intra-
ocular lenses are sold to the patients directly and if it could able to provide
some proof for such sale, then the exemption clause would be applicable.
12.At the out set, it is contended that if anybody including a dealer
or hospital selling the Intra-ocular lenses directly to the physically
disadvantaged persons, then exemption clause would be applicable and in
respect of other sales between the manufacturer and dealer, the exemption is
not available. This being the condition within the provision, there is no
irregularity or illegality on the part of the respondents in imposing sale tax
with reference to the transactions made by the petitioners, which all are
admittedly, not directly to the physically disadvantaged persons.
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W.P. Nos.4355 of 2008 etc., batch
13.In support of the said contention, the learned counsel for the
respondents referred to the judgment of the Hon'ble Supreme Court of India
in the case of Commissioner of Sales Tax vs. Pine Chemicals Ltd. reported
in (1995) 1 SCC 58 and the relevant paragraphs are as follows:-
“8.The idea behind Sub-section (2-A) of Section
8 of the Central Sales Tax Act, which we have analysed
hereinbefore, is to exempt the sale/purchase of goods
from the Central Sales tax where the sale or purchase of
such goods is exempt generally under the State sales tax
law. We must give due regard and attach due meaning to
the expression "generally" which occurs in the sub-
section and which expression has been defined in the
explanation. If the said expression had not been there, it
could probably have been possible to argue that
inasmuch as the goods sold by a particular
manufacturer- dealer are exempt from the State tax in
his hands, they must equally be exempt under the
Central Act. But Sub-section (2A) requires specifically
that such exemption must be a general exemption and
not an exemption operative in specified circumstances or
under specified conditions. Can it be said that the goods
sold by the dealers in this cases are exempt from tax
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generally under the State sales tax enactment? The
answer can only be in the negative. Such goods are
exempt from tax only when they are manufactured in a
large or medium industrial unit within five years of its
commencement of production and sold within the said
period, i.e., in certain specified circumstances alone.
The exemption is not a general one but a conditional
one. The exemption under the Government Order No.
159 is not with reference to goods or a class or category
of goods but with reference to the industrial unit
producing them and their manufacture and sale within a
particular period. For the purposes of the government
order, the nature, class or category of goods is
irrelevant; it may be any goods. It is concerned only
with the industrial unit producing them and the period
within which they are manufactured and sold. Can it be
said in such a case that it is an instance where the sale is
of goods, the sale or purchase of which is under sales
tax law of the appropriate State, exempt from tax
generally? Certainly not. Exemption provided by
Government Order No. 159, to repeat, is not with
reference to goods but with reference to the industrial
unit. So long as it is (i) a large or medium scale industry
and (ii) it manufactures and sells goods within the five
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years of its going into production, the sale of such goods
is exempt irrespective of the nature or classification of
goods. Similar goods may be manufactured by another
unit but if it does not satisfy the above two requirements,
the goods manufactured and sold by it would not be
entitled to exemption from tax. Indeed, the goods
manufactured by that very unit would not be eligible for
exemption if they are manufactured after the expiry of
five years from the date it goes into production and/or
sells them beyond the said period. The period of
exemption may also vary from unit to unit depending on
the date of commencement of production in each unit.
For the above reasons, we are of the opinion that the
exemption granted under the aforesaid government
order does not satisfy the requirements of Section 8(2-
A).
............
11.We may now refer to and examine the basis on
which the judgment under review holds that the
exemption granted by Jammu & Kashmir Government
Order No. 159 is a general exemption within the
meaning of Section 8(2-A) of the Central Sales Tax Act.
The Bench agreed that "the existence or otherwise of the
three limitations under the explanation above referred to
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on claiming exemption under Section 8(2-A) of the
Central Sales Tax Act will therefore, have to be tested
with reference to the transaction of sale or purchase as
the case may be" but then qualified the words "sale or
purchase, as the case may be", by adding "of the dealer
who claims the exemption in respect of his intrastate
sale or purchase of the same goods". It was further
added:
"Thus the specified circumstances and the
specified conditions referred to in the explanation
should be with reference to the local turnover of the
same dealer who claims exemption under Section 8(2-A)
of the Central Sales Tax Act".
In our respectful opinion, however, Sub-section
(2-A) speaks of sale or purchase of goods being exempt
generally under the State Sales Tax enactment; it does
not speak of exemption qua the dealer, much less qua the
unit manufacturing such goods. The exemption
notification issued by the Jammu & Kashmir
Government granted the exemption qua the industrial
unit manufacturing the goods and the period within
which they are manufactured and sold and not qua the
goods. In the judgment under review, it has been further
observed that:
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"The facts which the dealer has to prove to get
the benefit of the government orders are intended only to
identify the dealer and the goods in respect of which the
exemption is sought and they are not conditions or
specifications of circumstances relating to the turnover
sought to be exempted from payment of tax within the
meaning of those provisions, the specified circumstances
and the specified conditions referred to in the
explanation should relate to the transaction of sale of
the commodity and not identification of the dealer or the
commodity in respect of which the exemption is
claimed".
With respect, we are unable to appreciate the
above reasoning which is at variance with the clear an
simple language employed in Section 8(2-A). The
language of the sub-section does not bear or admit the
construction placed upon it in the judgment under
review. We are, therefore, of the opinion that the
judgment under review suffers from a manifest error of
law, an error apparent on the face of the record, and,
therefore, liable to be reviewed. We are also of the
opinion that in the interest of law, it is necessary that the
said error is rectified.”
14.Relying on the principles laid down by the Hon'ble Supreme
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Court of India in the judgment cited supra, the learned Government
Advocate for the respondents reiterated that the exemption contemplated
under the TNGST Act is unambiguous, as the aids for physically
disadvantaged persons alone are exempted. Thus, the Intra-ocular lenses
only if sold to the physically disadvantaged persons, then alone the
exemption could be applicable and not otherwise.
15.In reply, the learned counsels for the petitioners relying on the
very same judgment in Pine Chemicals Ltd. (supra) referred to the
following paragraph:-
“..........inasmuch as it was not a case where
goods were "totally exempt from tax". It was a case
where the exemption operated or was attracted only if it
was established that such goods were manufactured in a
large or medium industrial unit within five years of its
going into production and were sold within that period.
As pointed out hereinbefore, the exemption was not with
reference to goods but with reference to the unit
manufacturing the goods.”
16.The petitioners have stated that the respondents have not
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substantiated their contention that the exemption is conditional. Contrarily,
the language in the statute unambiguously clarifies that the exemption is
general in nature. Thus, there is no reason to claim tax in respect of the sale
of Intra-ocular lenses either to the dealer or to the hospital.
17.Considering the arguments as advanced by the respective learned
counsels appearing on behalf of the parties to the lis on hand, this Court is
of the considered opinion that whether the exemption granted is general in
nature or certain conditions are impliedly or expressly imposed is the point
to be considered.
18.Let us look into the Third Schedule to the TNGST Act, which
should be read along with Section 8 which provides exemption from tax.
Therefore, the object of Section 8 of the TNGST Act is to grant exemption
in respect of the goods and such exemption is subject to such restrictions
and conditions as may be prescribed by the appropriate Government.
Therefore, there is no further classification or condition is required in
respect of the grant of exemption. The Third Schedule to the TNGST Act
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unambiguously stipulates “goods exempted from tax by Section 8”. It
commences “the following goods produced or manufactured in India as
described in Column (3) against the relevant heading in column (1) of the
First Schedule to the Additional Duties of Excise (Goods of Special
Importance Act, 1957) (Central Act 58 of 1957)”. Therefore, Third
Schedule stipulates goods exempted from tax.
19.As far as the Intra-ocular lenses are concerned, Part-B is
relevant. Item No.2 of Part-B denotes “aids for physically disadvantaged
persons as notified by the Government”. Item No.2 did not prescribe any
goods within the meaning of Section 8 of the TNGST Act. Section 8
contemplates 'goods specified in the Third Schedule'. However, Item No.2
of Part-B did not prescribe any goods. Contrarily, the said Item states that
such goods, which all are aids for physically disadvantaged persons are to
be notified by the Government. Therefore, Item No.2 Part-B is a general
exemption granted, as far as the aids for physically disadvantaged persons
are concerned and what all are the aids which all are exempted were notified
by the Government in G.O.No.30 dated 27th March, 2005, viz., (i) electrical
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hearing aids and hearing-aid cords; (ii) simple spectacles sold to
Government for distribution at Government Free Eye Camps; (iii) Crutches,
wheel chairs, support sticks of all materials, prosthetics, artificial limbs and
parts and three wheelers with or without motor used by physically
handicapped person and cycle carriage for invalid persons; (iv) Intra-ocular
lenses; and (v) Orthotics.
20.Certain goods notified by the Government are capable of being
sold directly to the physically disadvantaged persons. Certain goods cannot
be sold directly, as such goods require an implantation by a qualified
Ophthalmologist Surgeon. Irrespective of these factors, the Court has to
find out for the purpose of grant of exemption from sale tax and such
technicalities regarding the medical implantation of the goods or otherwise
may not be required, nor concerned. However, it is admitted that Intra-
ocular lenses are exempted from sale tax as per Item No.2 of Part-B of the
Third Schedule to the TNGST Act.
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21.This Court has no doubt with reference to the language adopted
in Item No.2 of Part-B of the Third Schedule to the TNGST Act, which
contemplates “aids for physically disadvantaged person”. The aids for
physically disadvantaged may be many in numbers. However, such aids
notified by the Government alone are exempted under the statute more
specifically, Third Schedule. In the present case, five goods are exempted
from sale tax. Further, the Third Schedule to the TNGST Act commences by
contemplating “goods exempted from tax by Section 8”, Therefore, once a
particular goods is exempted from tax by Section 8, then such goods are to
be treated as generally exempted, unless there is an expressed restriction or
condition attached to the exemption clause. In the present case, there is no
such restriction or condition contemplated in Item No.2 of Part-B of the
Third Schedule. Item No.2 generally states 'aids for physically
disadvantaged persons as notified by the Government'. Thus, the
Government notified five goods which all are exempted and those five
goods are to be exempted generally and therefore, the condition now
suggested by the Government in their counter is presumptive and not
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supported with the provisions of the TNGST Act. Certain implied
conditions may be possible only on certain circumstances. In the present
case, the inference regarding any such implied condition cannot be drawn,
as the language employed in Item No.2 of Part-B of the Third Schedule is
unambiguous. It states 'aids for physically disadvantaged persons' and not
all the aids for physically disadvantaged persons are exempted. Only
certain aids alone are exempted for the physically disadvantaged persons
and such aids are five goods which are stipulated. Thus, as far as those five
goods are concerned, there cannot be any further restrictions or conditions,
whether it is sold directly to the disadvantaged person or through dealers.
In the absence of any specific condition to that effect, the respondents
cannot presume or assume and impose sale tax in respect of the Intra-ocular
lenses irrespective of the fact whether it is sold either to the dealer, hospital
or to the Doctor or otherwise.
22.As far as the exemptions in such cases are concerned, it is for the
benefit and welfare of the persons, who all are physically disadvantaged.
The exemption in general is granted, as such medical goods are to be
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supplied for the benefit of the common man including the poor. Intra-ocular
lenses are implanted in the eye (cataract).
23.Right to life is an integral part of Article 21 of the Constitution of
India. Thus, the State is bound to extend decent medical facility for the
welfare of the citizen in general. In this context, free medical treatments are
also provided by the appropriate Government. Therefore, the aids for
physically disadvantaged persons are once exempted and particular goods
are notified pursuant to the general exemption granted in Item No.2 of Part-
B of the Third Schedule, there cannot be any further restrictions or
conditions for the sale of such Intra-ocular lenses, as it finally reaches to the
physically disadvantaged persons and thus, this Court is of an opinion that
the concept of conditional exemption as contemplated by the respondents is
not traceable in any of the provisions of the TNGST Act, nor in the
notification. Once the goods are exempted under the TNGST Act, then it is
to be exempted under the CST Act also in view of Section 8 of the CST Act.
24.This being the constructive interpretation to be adopted in
respect of such exemption, which all are granted for the benefit of the group
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of people in general, this Court is of the opinion that if any such
presumptive condition is accepted, the same will cause inconvenience to the
physically disadvantaged persons and thus, the case of the respondents is to
be rejected.
25.It is made clear that the exemption, which is denied under the
provisions of the TNVAT Act is also to be extended to the extent mentioned
with reference to the provisions of the TNGST Act, which has been dealt
with in this judgment.
26.Accordingly, all the impugned orders are quashed and the writ
petitions stand allowed. No costs. Consequently, connected miscellaneous
petitions are closed.
15.07.2021
Index : Yes
Speaking Order
abr
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W.P. Nos.4355 of 2008 etc., batch
To
1.The Commissioner of Commercial Taxes,
Ezhilagam, Chepauk,
Chennai 600 005.
2.The Commercial Tax Officer,
Vadapalani-I Assessment Circle,
Chennai.
3.The Secretary to Government of Tamil Nadu,
Commercial Taxes and Registration Department,
Secretariat, Fort St. George, Chennai-9.
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W.P. Nos.4355 of 2008 etc., batch
S.M.SUBRAMANIAM, J.
abr
W.P.Nos.4355 of 2008, 36068 of 2004, 16051 of 2005,
4563, 5830, 5831, 8396 & 9011 of 2008, 21104 of 2009,
29013 to 29015 of 2011, 17 of 2014, 29404 of 2015,
22822 & 22823 of 2016, 762 & 763 of 2017, 3802,
11345 to 11347, 13428, 15964 & 16833 of 2018 and
W.P.(MD).Nos.4527 of 2009 & 5612 & 5613 of 2014
15.07.2021
https://www.mhc.tn.gov.in/judis/
