The Hon'ble High Court of Gujarat observed^[1] that an exemption entry should be liberally construed in accordance with the object sought to be achieved. That is, whether such provision is intended to grant incentive for promoting education or has some other beneficial reason behind it.

The exemption notification should be given a literal meaning. Recourse to other principles or canons of interpretation of statute should be resorted only if a plain reading results in anomaly or absurdity.

[1] Judgment dated February 18, 2022  in R/Special Civil Application No. 16476 of 2021