Holding

Exemption notifications are to be construed strictly, and the bracketed term ‘gold’ in ‘bullion and specie (gold)’ confines the concessional tax rate to gold bullion and gold specie only, thereby excluding silver bullion and specie.

Summary

Orient Traders, a dealer in silver bullion, challenged a reassessment that imposed a 2% sales tax for the year 1994-95, arguing that Government Orders (G.O.) No. 1092 (1994) and No. 252 (1995) which reduced the rate to 1.5% and 0.5% respectively, applied to both gold and silver bullion and specie. The State argued that the bracketed word “gold” in the phrase “bullion and specie (gold)” limited the concessional rate to gold bullion and gold specie only. The Supreme Court examined whether the bracketed term could be read as applying solely to “specie” and whether the later omission of “gold” in G.O. No. 625 (1996) altered the earlier intent. The Court held that “bullion and specie” is a single expression and the bracketed “gold” unmistakably restricts the benefit to gold, not silver, and that the omission in the 1996 order is effective only from August 1996, outside the relevant period. Consequently, the exemption notifications were to be construed strictly, and Orient Traders was not entitled to the reduced tax rate. The appeals were dismissed, requiring the appellant to pay tax at the standard 2% rate.

Issues considered

Whether the phrase “bullion and specie (gold)” in G.O. No. 1092 and No. 252 limits the reduced sales‑tax rate to gold bullion and gold specie, excluding silver.
Whether the bracketed word “gold” can be interpreted as applying only to “specie” and not to “bullion”.
Whether the omission of the word “gold” in G.O. No. 625 (effective from 01‑08‑1996) affects the interpretation of the earlier G.O.s for the assessment year 1994‑95.
How exemption notifications under the Andhra Pradesh General Sales Tax Act, 1957 must be construed – strictly or liberally.

Legislation cited

Andhra Pradesh General Sales Tax Act, 1957s. 14(4)(c), s. 9(1), s. Explanation I to First Schedule

Subjects

Andhra Pradesh General Sales Tax Actexemption notificationstatutory interpretationbullion and speciesales tax rate reductionstrict constructionsilver bulliongold bullionreopening assessmentreassessment

Judgment

[2008] 4 S.C.R. 810
•
A ORIENT TRADERS
V:
COMMERCIAL TAX OFFICER, TIRUPATI
(Civil Appeal No. 4491 of 2002)
MARCH 12, 2008
B
[ASHOK BHAN AND DALVEER BHANDARI,· JJ.]

· Andhra Pradesh General .Sales Tax Act, . 1957 - First
Schedule. Item 20 - G 0. Ms No. 1092 . dated 31. 10. 1994 and
c
'

252 dateq 19._5. 1995 reducing rate of sales tax from 2% to ~ ·
% on bullion and specie (gold) -Assessee, dealing in silver
bullion claiming benefit under· the G. 0. for A Y 1994-1995 -
Plea that reduced rate of sale tax under G 0. applicable to
both gold and silver bullion and bracketed words 'gold' applies
only to specie and not to bullion -- Held: Not justified and
0
tenable - There is no ambiguity in the expression used in the
G.O. - Intention of State Government is clear that only gold
bullion arid specie entitled to·concessional rate of tax- 'Bullion
and specie' is one single phrase and canndt be bifurcated -1t
E cannot be said that word 'gold' is referable to 'specie' only as it
is mentioned after word 'specie' - Also benefit of G 0. Ms No.
625 dated 3f 7. 1996 omitting bracketed word 'gold' cannot be
sought since G 0. was effective from 01. 08. 1996 - Hence,
assessee not entitled to the benefit - Exemption Notifications
G 0. Ms No. 1092 dated 31.10.1994, and G 0. Ms No. 252
F dated 19.5.1995.
Interpretation of Statutes - Taxing statutes - Exemption
Notifications - Construction of - Held: Are to be construed
strictly - If intention of legislature is unambiguous, then courts
G should not add words in exemption notification to extend the
benefit to items not mentioned in the Notification.
Under item 20 of the First Schedule of the Andhra
Pradesh General Sales Tax Act, 1957 the bullion and
specie are taxable at the rate of 2% with effect from
H 810
ORIENT TRADERS v. COMMERCIAL TAX OFFICER, 811
TIRUPATI [BHAN, J.]
-r-
8.7.1983. By Notification in G.O. Ms. No. 1092 dated A
31.10.1994 rate of sales· tax was reduced on the sale of
bullion and specie (gold) from 2% to %% net. Thereafter,
the sales tax on bullion and specie was raised to 4% w.e.f.
01.04.1994. Again by Notification in G.O.Ms. No. 252 dated
19.5.1995 rate of sales tax on bullion and specie (gold) B
was reduced to half percent. Subsequently by G.O.Ms No.
625 dated 31.7.1996 the expression 'gold' in the bracket
immediately after the term 'gold and specie' occurring in
the aforesaid G.O.'s was omitted.
Appellant-dealer in silver bullion, filed return showing c
a turnover of Rs. 14,33,01,470/- and paid% percent sales
tax for the assessment year 1994-95. The Assessing
Authority accepted the return. Theteafter, in view of the G.
0. Ms No. 1092 and 252, the Assessing Authority issued
,..J.
notice to the appellant for re-opening the assessment and D
~
bring the turnover to tax at the rate of 2%. Appellant
challenged the notice. High Court dismissed the writ
petition on the ground of alternate remedy of filing the
objections. Thereafter, appellant filed objections that the
reduced rate of sale tax under the G. 0. was applicable E
not only to gold bullion but also to silver bullion and that
the bracketed words 'gold' used in the G. 0. applies only
to specie and not to bullion. Assessing Officer rejected
the objections and framed the re-assessment. Appellant
.)(
• challenged the re-assessment by filing writ petition which F
was dismissed. Hence the present appeals.
Dismissing the appeals, the Court
HELD: 1.1 Entry 20 of the First Schedule of the the
Andhra Pradesh General Sales Tax Act, 1957 refers to levy
G
of the tax at the point of first sale on bullion and specie.
Explanation. I under the First Schedule provid.es the
meaning of the expression 'bullion' as pure gold or silver
and includes gold or silver mixed with copper, lead or any
other kind of base metal. While issuing· Notification No.
H
I
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812 SUPREME COURT REPORTS [2008] 4 S.C.R.

A 1092 dated 31.10.1994, the rate of tax was reduced· on the
sale of bullion and specie (gold) from 2% to %% net. The
Legislature used the term 'gold' in bracket after expression
'bullion and specie' thereby making its intention clear that
it wanted to restrict the benefit of reduced rate of tax to
B gold bullion and specie only and not to silver. Had the
intention been to extend the benefit of reduced rate of tax .
to silver bullion and specie, then, there was no need to
put the word 'gold' in brackets after 'bullion and specie'.
The submission that the word 'gold' is referable to specie
c only as it finds mention after the word 'specie', cannot be
accepted. "Bullion and specie" is one single phrase and
the same cannot be bifurcated. (Para 15 and 16) [820-8-F]
1.2 The submission that bracketed word 'gold'
contained in Clause (a) of G.O.Ms No. 1092 dated
D 31.10.1994 and G.0.Ms No. 252 dated 19.05.1995 having
been omitted by G.0.Ms No. 625 dated 31.07.1996 clearly
shows that the intention of the Legislature was that the
concessional rate of tax is to be applied to both gold and
silver bullion species for the period in question, cannot
E be accepted. G.O.Ms No. 625 dated 31.07.1996 has been
made effective from 01.08.1996. The relevant period in the
present appeals is from 01.11.1994 to 31.03.1995. Hence,
the appellant cannot take any benefit of omission of the
word 'gold' in brackets for the period in question. (Para 17)
F [820-G, H; 821-A, B]
1.3 The exemption notifications are to be construed
strictly. If the intention of the legislature is clear and
unambiguous, then it is not open to the courts to add
G words in the exemption notification to extend the benefit
to other items which do not find mention in the notification.
In the instant case, there is no ambiguity in the expression
used in the G.O. The intention of the State Government is
clear that only gold bullion ana specie is entitled to the
H concessional rate of tax. Under the circumstances, the
•
e
ORIENT TRADERS v. COMMERCIAL TAX OFFICER, 813
TIRUPATI [BHAN, J.]

same cannot be extended. to the silver as claimed by the A
· assessee. (Para 18) ·[821-C, D, E]
Deputy Commissioner of Sales Tax v. Mis. G. S. Pai and
Co. 1980 (1) sec 142 - relied on.
State of Jharkhand & Others v. Tata Cummins Ltd., and B
another, 2006 (4) sec 57 and Kartar Rolling Mills v.
Commissioner of Central Excise, New Delhi 2006 (4) SCC
772 - referred to.
CIVIL APPELLATE JURISDICTION: Civil Appeal No. C
4491 of 2002.
From the final Judgment and Order dated 27 .04.2001 of
the High Court of Judicature of Andhra Pradesh at Hyderabad
in W.P. No. 1727of1997
WITH D
~ Civil Appeal Nos. 4492 of 2002, 4493 of 2002 and 4494
of 2002
S.K. Bagaria, A. Mariarputham and Aruna Mathur (for M/
s.ArputhamAruna & Co.) fortheAppellant. E
Anoop G. Choudhari and June Choudhari, Manoj Saxena
(for Guntur Prabhakar) for the Respondent.
The Judgment of the Court was delivered by
... F
BHAN, J. 1. This judgment shall dispose of Civil Appeal
No 4491 of 2002 filed against a detailed order by which the
High Court has dismissed the Writ Petition filed by the appellant
and the three connected appeals which have been filed by the
Assessees against the dismissal of their writ petitions by the G
High Court following the impugned Order in C1v1I Appeal No.
4491 of 2002.
2 Facts are taken from Civil Appea1 No 4491 of 2002,
which rs the main appea1.
H
I

e
814 SUPREME COURT REPORTS [2008] 4 S.C.R.

A · · 3. Th~'-relevant period is from Nove,;,ber, 1994 to March,
1995 which falls in the Assessment Year 1994-95. The appellant.
deals: in the sale of silver bars. It filed its r.etum showing a turnover
of Rs.14,33,01,470/- and paid sales tax.atthe rate. of%%. The ·
f.\s~essing Aut~ority accepted the sa.id return and comp.leted
B the' a~sessment on 27 .11.1995 .. Later, the Assessing Officer
i_ssued roti(?e bn 17.8.1996 proposing to reopen the assessment
under'Sedlori 14(4)(c) of th·e Andhra Pradesh General Sales
Tax Act, 1957 (for short "the Act") and bring the above turnover
tota~ at the rate of 2%·, apart from additi9.nal tax and surcharge,
c on the premise that G.O. Ms No. 1092 and G.O. Ms No. 252
reducing the rate of sales tax to %% were applicable only to
gold·bullton ·and the same were not applicable to silver bullion
and' spede.· Questioning the said show cause notice, the
appellant filed W.P. No. 21503 of 1996. The High Court
dismissed the writ petition on the ground of alternate remedy of
0 filing the objection and getting a decision from the authorities
under the Act o·n merits. The appellant thereafter filed objections
claiming that the reduced rate of sales tax under the G.O. was
appli(!able l)Ot. only to gold bullion but also to silver bullion. That
the bracketed words "gold" used in the above G.O. applies only
E to specie and not to bullion. The Assessing Officer rejected the
contention of 'the assessee and framed the re-assessment.
Questioning the said re-assessment, the appellant filed Writ
Petition No. 1727 of 1997 which has been di.smissed by the
impugned order. · ·
F
4. It was stated i~ the writ petition that though a remedy of
·appealwas, available'";'. but ·the. said remedy by way of appeal
w(>'uld not be effective. In ·the light of th·e clarification issued by
the Commissioner df c·ommercial Tax by his order dated
G 22.3.1995, clarifying that the G.O.Ms No. 1092 is applicable
only to the gold bullion and not to silver bullion. It was also
contended that the issue relates only to the interpretation of
G.Os:, therefore, to have effective and binding decis.ion the
appellant has approached the High Court by filing the writ petition.
The said writ petition was entertained. It has been dismissed
H
ORIENT TRADERS v. COMMERCIAL .TAX OFFICER, 815
TIRUPATI [BHAN, J.]

on merits .. A
5. ·it is not in dispute that the appellant is a dealer in silver
bullion. Under ltem-20 of the First Schedule to the Act the original
rate prescribed is 2%. However, the State Government issued
Notification under Section 9(1) of the Act in G.0.Ms. No. 1092
dated 31.10.1994 reducing the rate of sales tax to Y2% in respect B
of 'bullion and specie (gold)' from the date of the said
Notification. In order to appreciate the controversy in issue, it
would be necessary to refer to the Entry in the First Schedule to
the Act as well as the Notification issued on 31.10.1994. Entry
20 in First Schedule to the Act reads :- C
FIRST SCHEDULE

SI. Description of Point of levy Rate of Effective
·No. goods tax from
D
20· Bullion and Atthe point 2 8-7~1983
specie (1020) of first sale 4 1-4-1995
.. in the State

6. The expression 'bullion' in Entries 20 and 21 has been
defined in Explanation I to the First Schedule which reads:- · E
"Explanation-1 :-The expression 'bullion' in it~ms 20 and
21 means pure gold or silver and includes gold or silver
mixed with copper, lead or any other kind of base metal."
,.,'< 7. The relevant portion of G.O.Ms. No. 1092 Rev. (CT-II) F
dated 31-10-1994 is extracted hereunder:-
"Notification-1 .
In exercise of the powers conferred by the sub-section (1)
of Section 9 of the Andhra Pradesh General Sales Tax· G
Act, 1957 (Act-VI of 1957), the Governor of Aridhra
Pradesh hereby directs:
(a) that the tax leviable under the said Act on the said Act
on the sale of bullion and specie (gold) be reduced from
2% to 112 %, all included (net 112%); H
816 SUPREME COURT REPORTS [2008] 4 S.C.R.
•
A (b) that the tax leviable under the said Act on the sale of
jewellery, including those set with precious stones be
reduced to 2%; . 1 .·

(c) that the tax ·1eviable under:the said Act on the sale of
precious stones loose, other than pearls, be reduced to
B 2%.
This notification shall come into force with immediate
effect." ~·
(Emphasis supplied)
C 8. ·The subsequent Notification issued u/s. 9(1) dated
19.5.1995 which came into force with effect from 1.4.1995 and
the Notification subsequent thereto in G.0.Ms No. 625 dated
31. 7 .1996 superseding the earUer Notification omitting the
expression 'gold' (G.O.Ms. Nos: 1092 and 252 of 1995)
D occurring in the bracket, are not reproduced as the same are
not relevant for the purposes of disposing of the present
appeals.
9. Learned counsel for the appellant contends that the
perusal of G.Os. issued by the State of Andhra Pradesh clearly
E shows that the bracketed word 'gold' occurs only after 'specie'
and not either before or after 'bullion'. Therefore, the said
bracketed word ··gold' is relevant for the word 'specie' only and
not for the word ~bullion'. If the G.O. is so interpreted; the reduced
rate of sales tax would be available t6 the appellant at }'2% as
F provided therein, which was accepted by the Assessing Officer
at the first instance. That there was no reason for the Assessing
Officer to change his opinion to revise the assessment levying
the sales tax at higher rate. Relying upon the G.O. Ms. No. 625.
dated 31.7.1996 which omitted the expression 'gold' from the
G bracket immediately after the term 'specie', it was contended
that the Government did not intend to give the benefit of lower
rate of tax only to gold but also to silver bullion. The action of the
respondent-authorities in re-opening the assessment as well
as framing the reassessment is not in accordance with law and
i,~ is only a change of opinion with reference to the Notification
1
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ORIENT TRADERS v. COMMERCIAL TAX OFFICER, 817
TIRUPATI [BHAN, J.]

issued by the Government under Section 9(1) of the Act. It was A
also contended that the Notification was clear and unambiguous
and the benefit granted in the Notification would be available to
the dealers dealing in silver bullion as well. If the G.Os. are
interpreted in this manner, then no case was made out to revise
the assessment to levy the higher rate of tax. Reliance was B
placed on a decision of this Court in Commissioner of Sales
Tax V. Industrial Coal Enterprises, 1999 (2) SCC 607.
~
10. As against this, the learned counsel appearing for the
Revenue submits that there is no justification to contend that
the term 'gold' is applicable only to specie and not to bullion. c
According to him, the interpretation sought to be put by the
appellant to the G.O. is not proper and correct. It is submitted
that 'bullion and specie' is one single phrase and they cannot
be bifurcated. The intention of the Government in the said G.O.
was to apply the reduced rate of tax to gold bullion and specie D
_...._
only. As these two words constitute one single phrase the word
•• 'gold' was bracketed at the end to indicate that it is meant to be
applicable to gold only. It was also submitted that Commissioner
of Commercial Tax, Government of Andhra Pradesh by its order
dated 22.3.(1995 passed on a request made by the Twin Cities E
Jewelers Association clarified that the reduced rate of tax is
applicable only to gold bullion and specie. As such the contention
of the appellant that it is also applicable to silver bullion is
unjustified and untenable.
'(
11. Learned counsel for the parties have been heard at F
"
length.

12. Bullion and specie are taxable at the rate of 2% with
effect from 8. 7 .1983 under item 20 of the First Schedule of the
Act. Same rate is applicable to the articles and jewellery
G
mentioned under Entry 21 made out of bullion and/or specie or
both, excluding precious stones. Explanation I to the said
~ Schedule defines bullion as pure gold or silver and includes
gold or silver mixed with copper, lead or any other kind of base
metal. The Government of Andhra Pradesh by issuing G.O. Ms.
H
•
e
818 SUPREME COURT REPORTS [2008] 4 S.C.R.

A No. 1092 dated 31.st October, 1994 under Section 9(1) of the
Act reduc;;ed· the net rate of sales tax to %% on sale of bullion
arid specie (goldr Andhra Pradesh General Sales Tax Act was
amE:mded by Act 22 of 1995 with effect from 1st April, 1995
prescribing the sales tax in the case of bullion and specie at the
B rate.of 4%. Again the Government issued a Notification under
Section 9(1) of the Act in G.O.Ms. No. 252, dated 19.5.1995
reducing .the· rate of sales tax in the case of bullion and specie
(gold) to%% with effect from 1.4.1995. Subsequent G.O.Ms No:
625 dated 31. 7.1996 was issued by the State of Andhra Pradesh
C omitting the expression 'gold' in the bracket immediat~ly after
the term 'gold and specie' occurring in G.0.Ms Nos. 1092 of
1994 and 252 of 1-995.
13. This Court in the case of Deputy Commissioner of
Sales .Tax v. iVl/s. G.S. Pai and Co. I 1980 ( 1) sec 142'
D considered the terms 'bullion and sp~cie', in a different conte)(i
i.e., ·whether ornaments and other articles of gold could be
.re·ga·rded as bullion and specie. as .specified in EntrY 56 of .the
·First Schedule ofthe Kerala General Sales Tax Act, 1963. This
Court held iri para
. . .. ~ . '
3. as
.
under::-.
E "We will.first consider the question whether the ornaments
· and other articles of gold purchased by the assessee fall
within the description of "Bullion and specie" given in Entry
· 56. There are two expressions in this Entry which require
consideration; one is "bullion" and the other is "specie".
F . Now there is one cardinal rule of interpretation whi9h has
always to _be borne in mind while interpreting entries in
·.sales tax leg.islation· ahd it is that the words used in the
entries must be construed not in any technical sense nor
from the scientific point of view but as understood in
G common parlance. We must give the words used by the
Legislature-their popular sense meaning "that sense which ·
· people conversant with the subject-matter with which the
statute is dealing would·attri~ute to it". The word "bullion"·
must, therefore, be ·interpreted according to ordinary ·
H parlance and must be given a meaning which people
•
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ORIENT TRADERS v. COMMERCIAL TAX OFFICER, 819
TIRUPATI [BHAN, J.]

conversant with this commodity would ascribe to it. Now A
it is obvious that "bullion" in its popular sense cannot include
ornaments or other articles of gold. "Bullion" according to
its plain ordinary meaning means gold or silver in the. mass.
It connotes gold or silver regarded.as raw material and it
may be either in the form of raw gold or silver or ingots or B
bars of gold or silver. The Shorter Oxford .Dictionary gives.
the meaning of "bullion" as "gold or silver in the Jump; also
applied to coined or manufactured gold or silver
considered as raw material." So also in Jowitt's Dictionary
of English Law and ~harton's Law Lexicon we find that c
the following meaning is given for the word "bullion":
"uncoined gold and silver in the mass. These metals are
called so, eith.er when melted from the native ore and not
perfectly refined, or where they are perfectly refined, but
melted down into bars or ingots, or into any unwrought
body, of any degree of fineness". It would, therefore, be D
seen that ornaments and other articles of gord cannot be
regarded as "bullion" because, even if old and antiquated,
they are not raw or unwrought gold or gold in the mass; but
they represent manufactured or finished products of gold:
Nor do they come within the meaning of the expression E
"specie". The word "specie" has a recognized meanin·g.
and according to Webster's New World Dictionary, it
means "coin, as distinguished from paper· money;'. The
Law Dictionaries also give the same meaning. Wharton's
Law Lexicon and Jowitt's Dictionary of English Law state F
the meaning of "specie" as "metallic· money" and in Black's
Law Dictionary, it is described as ."coin of the p~eci~us
metals, of a certain weight and fineness, and bearing the
stamp of the Government, denoting its value as currency"
while "Words and Phrases Permanent Edition-Vol. 39A" G
also gives the same meaning. Therefore, according to
common parlance, the word "specie" means any metallic
coin which is used as currency and if that be the true
meaning, it is obvious that ornaments and other articles of
gold cannot be described as "specie" ....... "· H.
I

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820 SUPREME COURT REPORTS [2008] 4 S.C.R.

A 14. From the reading of the above judgment, it is clear
i< ..•
that 'bullion' means gold or silver in mass, in bars, plates etc., in
uncoined form; whereas 'specie' means coined gold or silver
or any other metal and also used as currency. The distinction
between the two expressions is that the former refers to gold
s and· silver when it is in bulk form, either unshaped or shaped
like bars, plates etc., whereas later refers to the coined form of
silver or gold.
15. Entry 20 of the First Schedule refers to levy of the tax
at the point of first sale on bullion and specie. Explanation I under
C the First Schedule provides the meaning of the expression
'bullion' as pure gold or silve.r and includes gold or silver mixed
with copper, lead or any other kind of base metal. While issuing
Notification No. 1092 dated 31.10.1994, the rate of tax was
reduced on the sale of bullion and specie (gold) from 2% to%%
D net. The Legislature used the term 'gold' in bracket after
expression 'bullion and specie' thereby making its intention clear
that it wanted to restrict the benefit of reduced rate of tax to gold
bullion and specie only. Had the intention been to extend the
benefit of reduced rate of tax to silver bullion and specie, then,
E there was no need to put the word 'gold' in brackets after 'bulliEm
and specie'. · · ',-

16. Contention that the word 'gold' is referable to specie
only as it finds mention after the word 'specie', cannot be
accepted. "Bullion and specie" is one single phrase and the
F same cannot be bifurcated, as contended by the counsel for
the appellant. The intention of the Government in putting the word
'gold' in the bracket after the words 'bullion and specie' clearly
shows that the intention of the Government was to extend the
benefit of reduced rate of tax to gold bullion and gold specie
G only arid not to silver. The word 'gold' was put in brackets to
indicate that the concessional rate of tax is applicable only to
the gold in either of the two forms Le. bullion or specie.
17. Contention of the learned counsel for the appellant that
H bracketed word 'gold' contained in Clause (a) of G.O.Ms No.
~
' ORIENT TRADERS v. COMMERCIAL TAX OFFICER,
TIRUPATI [BHAN, J.]

1092 dated 31.10.1994 and G.O.Ms No. 252 dated 19.05.1995
having been omitted by G.O.Ms No. 625 dated 31.07.1996
821

A

clearly shows that the intention of the Legislature was that the
concessional rate of tax is to be applied to bolh gold and silver
bullion species for the period in question, cannot be accepted.
G.O.Ms No. 625 dated 31.07.1996 has been made effective B
from 01.08.1996. The relevant period in the present appeals is
from 01.11.1994 to 31.03.1995. Hence, the appellant cannot
take any benefit of omission of the word 'gold' in brackets for
the period in question as the G.O.Ms No. 625 dated 31.07.1996
is to take effect from 01.08.1996. c
18. It is well established principle that the exemption
notifications are to be construed strictly, reference may be made
to State of Jharkhand & Others V. Tata Cummins Ltd., and
another, 2006 (4) SCC 57 and Kartar Rolling Mills V.
Commissioner of Central Excise, New Delhi, 2006 (4) SCC D
772. If the intention of the legislature is clear and unambiguous,
then it is not open· to the courts to add words in the exemption
·'¥°' . notification to extend the benefit to other items which do not find
mention in the notification. In the present case, there is no
ambiguity in the expression used in the G.O. The intention of the E
State Government is clear that only gold bullion and specie is
entitled to the concessional rate of tax. Under the circumstances,
the same cannot be extended to the silver as claimed by the
assessee.
19. For the reasons stated above, we do not find any merit F
)f
in these appeals and dismiss the same with costs.
""
N.J. Appeals dismissed.