ABDUL NAZEER, J. ( 1 ) PETITIONERS in these cases have called in question the demand of tax made by the Regional Transport Officer, Bangalore and confirmed by the Deputy Commissioner of Transport, Bangalore in respect of different vehicles. ( 2 ) THE brief of the cases are as follows: ( 3 ) PETITIONERS are Registered Owners of All India Tourist Vehicles covered by All India Tourist Vehicle Permits issued under Sub-Section (9) of Section 88 of the Motor Vehicles Act, 1988 valid throughout the territory of India. The petitioners have claimed exemption from payment of tax by filing Non-use intimation before the 1st respondents in Form No. 30 on the ground that they are parked for repairs outside the State of Karnataka. The 1st respondent has issued endorsements rejecting the said applications stating that in order to claim exemption from payment of taxes as per the Notification No. HTD 170/tma 2003 dated 06. 08. 2003 the Registered Owners are required to keep the vehicles in question under non-use within the State of Karnataka and that the vehicles parked outside the State of Karnataka for repairs and for body building arising out of an accident alone are entitled for exemption from payment of taxes. Feeling aggrieved by the said order the petitioners have filed appeals before the 2nd respondent which are also dismissed. ( 4 ) I have heard Sri. B. R. Sundararaja Gupta, Learned Counsel for the Petitioner and Sri. B. T. Parthasarathy, Learned Advocate General along with Niloufer Akber, Learned High Court Government Pleader for the respondents. ( 5 ) LEARNED Counsel for the petitioners submits that having regard to Clause (5) of the Notification at Annexure 'a' three categories of the Motor Vehicles kept outside the State of Karnataka are entitled for exemption. They are (i) Motor vehicles involved in the accident, (ii) Motor Vehicles parked for repairs and (iii) Motor Vehicles kept for body building purposes. Learned Counsel emphasizes the use of Comma between the Words 'accident' and 'parked' at Clause (5) of the skid Notification and submits that since the vehicles in question are parked outside the State of Karnataka for the purpose of repairs, they are entitled for exemption. ( 6 ) ON the other hand, Learned Advocate General appearing for the respondents submits that the object of issuance of the Notification dated 06. 08. ( 6 ) ON the other hand, Learned Advocate General appearing for the respondents submits that the object of issuance of the Notification dated 06. 08. 2003 was to enable the motor vehicles involved in the-accident and parked for repair purposes and body building to claim exemption when, they are kept outside the State of Karnataka. It is further submitted that the department has noticed that there Was a large scale misuse of the vehicles declared under that there was a large scale misuse of the vehicles declared under non-use outside the State of Karnataka and were being plied on public roads clandestinely even during the period for which tax exemption has been availed from the concerned Taxation Authorities on the ground of non-user. It is further argued that when the motor vehicles the authorities was not possible having regard to the fact that the territorial jurisdiction of the offices in the department does not extend. Beyond the State of Karnataka. Further, during the period when the non-user declaration is in force, the Inspection of Motor Vehicles are required to a watch on the vehicles under producer by periodically visiting the places of garage at regular intervals. This exercise is not possible in respect of vehicles, garaged outside the State. Learned Advocate further submits that keeping in view of the said practical difficulties in view and in order to plug the loopholes in the earlier Notification dated 11. 08. 1980, the State Government has issued the notification dated 06. 08. 2003, imposing certain additional conditions. It is his further submission that the entire Notification has to be read for the purposes of ascertaining the true meaning of Clause (5) of the Notification. ( 7 ) I have carefully considered the arguments of the Learned Counsel made at the Bar. ( 8 ) THE material facts are not in dispute. It is not in dispute that the vehicles in question have, not met with any accident. It is case of the Petitioners that the vehicles are kept outside the State of Karnataka for repairs due to break down. Therefore, the only question to be considered is whether they are entitled for from payment of tax as provided under the Notification, dated 06. 08. 2003? ( 9 ) SECTION 16 of the Karnataka Motor Vehicles Taxation Act (for short, Act'): empowers the State. Therefore, the only question to be considered is whether they are entitled for from payment of tax as provided under the Notification, dated 06. 08. 2003? ( 9 ) SECTION 16 of the Karnataka Motor Vehicles Taxation Act (for short, Act'): empowers the State. Government to issue Notification exempting, or producing payments, prospectively or retrospectively the tax payable in respect of any Class of Motor Vehicles or Motor Vehicle not used on the roads. It also empowers the State government by Notification to reduce the road tax payable in respect of any class of Vehicles plying on the routes specified in the on, the routes specified of the opinion that it is necessary in the public interest so to do. The State Government had issued Notification in accordance with the said Section in No. HTD 95 TMT 7700 dated 11. 09. 1980 exempted the motor vehicles registered under the State of Karnataka and not intended to be used on the routes from the payment of taxes subject to certain conditions stated therein. Again a fresh notification dated 06. 09. 2003 was 'issued in supersession of 'the notification dated 11. 09. 1996. The said notification is under: "notification UNDER KARNATAKA MOTOR vehicles TAXATION ACT, 1957 notification no. HTD 170 TMA 2003, Bangalore, dated 6th August, 2003 karnataka Gazette, Extraordinary No. 1011, dated 27-8-2003 in exercise of the powers conferred by sub-clause (ii) of clause (a) of sub-section (1) of section 16 of the Karnataka Motor Vehicles Taxation Act, 1957 (Karnataka Act 35 of 1957), and in supersession of Notification No. HTD 95 TMT 77 (ii), dated 11-9-1980), the Government of Karnataka being of the opinion that it is necessary in the public interest so to do, hereby exempt motor vehicles registered in the State of Karnataka and not used on roads, from the payment of tax under the said Act for a period of one full quarter, half-year or 7 one year, as the case may be, during which such, vehicles are; not used on roads, subject to the following conditions, namely: 1. Non-use of the motor vehicle shall be intimated in person or by Registered Post Acknowledge due before the commencement of the quarter half-year or one year as the case may be, in Form 30 as per Rule 34-A of the Karnataka Motor Wicks Taxation Rules, 1957 along with the fee prescribed. 2. Non-use of the motor vehicle shall be intimated in person or by Registered Post Acknowledge due before the commencement of the quarter half-year or one year as the case may be, in Form 30 as per Rule 34-A of the Karnataka Motor Wicks Taxation Rules, 1957 along with the fee prescribed. 2. The Registration Certificate, Taxation Card and permit, if any, in it aspect of -the motor vehicle shall be surrendered to the Regional Transport Officer comprised, along with the application. Provided that where such documents are seized or retained by any authority, a certificate obtained from such authority regarding such seizure or retention shall be produced. 3. In case of a motor vehicle covered by, hypothecation or hire-purchase agreement or lease agreement. If the motor vehicle is seized by the financier and, the document relating to it are not with the applicant, the non-use shall be intimated, concerned Regional Transport officer with a declaration of non a violability, of documents in Form 30 with the prescribed fees. Before release of the motor vehicle, the financier shall produce the original documents or fresh registration certificate of the vehicle. 4. Address proof or consent letter of the garage owner where the vehicle is intend to be kept during the period of non-use shall be produced for physical verification of the vehicle. 5. Except the vehicles involved in accident, parked for repair purpose or body building purpose, all other motor vehicles should be kept within the State of Karnataka in the jurisdiction of any registering authority. 6. The period of non-use of vehicle shall not exceed more than five years from the date of declaration in Form 30. The authorities are empowered to take action to cancel the registration certificate after verifying the condition of the vehicle. 7. The motor vehicle shall not be removed during the period of exemption from the place where the motor vehicle is kept without the prior permission of the concerned Regional Officer. 8. The Regional Transport Officer or any other Officer authorized by him in this behalf, shall have the power to inspect the motor vehicle with reference to the chassis number in the place where the motor vehicle is kept to satisfy himself regarding the nonuse of such motor vehicle. 9. 8. The Regional Transport Officer or any other Officer authorized by him in this behalf, shall have the power to inspect the motor vehicle with reference to the chassis number in the place where the motor vehicle is kept to satisfy himself regarding the nonuse of such motor vehicle. 9. If no such inspection, the motor vehicle is not found at the place where it is intimated to have been kept, exemption from payment of tax' for the entire period of surrender shall not be available in respect of such vehicle. ( 10 ) AT the time of return of documents to the registered owner, after the expiry of the period of such non-use of the motor vehicle, the Regional Transport Officer shall cause an entry to be made in the taxation card specifying the period during which the motor vehicle was under non-use. Procedure to be forward for the Accident, Theft, Seizure and Confiscated Vehicles1. In case the motor vehicle meets with an accident, the owner or person in possession of the vehicle shall intimate the jurisdiction at Regional Transport Office, the non use of the vehicle with copy of the First Information Report issued by the concerned Police Officer. 2. If any motor vehicle is confiscate or seized by the Central or State Government, the non-use shall be intimated for the purpose of claiming exemption from payment of tax. The matter should be confirmed from the concerned authorities regarding seizure and release of the vehicle. 3. In case of theft of any motor vehicle, the matter should be intimated to the concerned jurisdictional Regional Transport Officer by filing Form 30 along with the prescribed fee documents of the vehicle and copy of the First information Report for the purpose of claiming exemption from payment of tax. This Notification shall come into force with effect from the date of publication in the Official Gazette". 10. In the case of Collector Of Central Excise, Mumbai Vs. Karle Exports Pvt. Ltd 75 STC Page 105), the Apex Court has held that when a Notification is issued in accordance with the power conferred by the Statute, it has a statutory force and: validity and therefore, it is as if the exemption under the Notification were contained in the Act itself. Karle Exports Pvt. Ltd 75 STC Page 105), the Apex Court has held that when a Notification is issued in accordance with the power conferred by the Statute, it has a statutory force and: validity and therefore, it is as if the exemption under the Notification were contained in the Act itself. It is further held that the fairest and most rational method to interpret, the will of the law maker is by exploring his intentions at the time, when the law was made. For that purpose, notification must be read as a whole in the context of other relevant provisions. ( 11 ) IT is well settled that in construing an enactment, particularly an amending provision, it is permissible so have regard and sometimes, it may be necessary to look into the history of the amendment and the reasons which led to its enactment. It would then be pertinent to see what was the evil or mischief that existed before and had to be cured and how the cure and remedy has been provided. (See, between Burma Shell Co Ltd. , Vs. State Of Madras 21 STC 227 ). ( 12 ) AS noticed-above, the non-user conditions were earlier governed by notification dated 11. 09. 1980. As submitted by the learned Advocate General, the experience of the department is that there was a large scale misuse of vehicles declared under non-use outside State of Karnataka and mere being piled on public road clandestinely within the period in which tax exemption has been effected from the concerned Taxation Authorities on the ground of non-user. It is also felt that when the not or vehicles are garaged outside the State supervision and control by the Authorities concerned was not possible having regard to the fact that the territorial jurisdiction of the office in the Transport Department of the State does not extend beyond the State of Karnataka and during the period when the non-user declaration is in force. The authorities concerned are required to keep a watch on the vehicles under non-use by periodical visiting the place of garage at regular intervals. If the vehicles are kept outside the State this exercise is not possible. Keeping in view of the practical difficulties involved and in order to plug the loopholes in the earlier notification dated 11. 08. The authorities concerned are required to keep a watch on the vehicles under non-use by periodical visiting the place of garage at regular intervals. If the vehicles are kept outside the State this exercise is not possible. Keeping in view of the practical difficulties involved and in order to plug the loopholes in the earlier notification dated 11. 08. 1980 the State Government has issued the present notification, imposing certain additional conditions and the tax exemption is granted under non-user only for them vehicles which am garaged in, the State of Karnataka. However, the, notification has exempted the vehicles involved in the accident from the restriction of being garaged within the State of Karnataka and in respect of any other vehicles if the tax exemption is claimed, in the State of Karnataka. Looked at from this background the reasonable. And probable viewing to be assigned to Clause (5) is, that only a motor vehicle, involved in an accident, requiring, repairs or body building purpose, parked outside. , State of Karnataka is eligible for exemption from payment of tax on the ground of non-user. In all other cases, the motor vehicle should be kept within the State of Karnataka 'within the jurisdiction of any registering authority in order claim exemption. ( 13 ) AT this stage, Mr. Gupta, Learned Counsel lays great stress on the use of Comma at Clause (5) and submits that even if the vehicles are packed outside the State of Karnataka for repairs or body building they are, entitled for exemption. He further contends that by the use of a Comma after the word 'accident' in Clause (5) is indicative of the legislature that the vehicles parked outside the State of Karnataka for repair and-body building are also entitled for exemption. ( 14 ) A Comma is put as per the Rules of Grammar. It indicates a slight pause or break between parts of a sentence. It is well established that a punctuation is a minor element in the construction of a statue. It cannot be regarded as controlling element for determining the meaning of a statute. In the case Of Lewis Pugh Evans Pugh Vs Ashutosh Sen And Others AIR 1929 PC 69 is held that commas are no-part of the statute. In the case of Ashwind Kumar Ghose And Another Vs. It cannot be regarded as controlling element for determining the meaning of a statute. In the case Of Lewis Pugh Evans Pugh Vs Ashutosh Sen And Others AIR 1929 PC 69 is held that commas are no-part of the statute. In the case of Ashwind Kumar Ghose And Another Vs. Arabinda Bose And Another AIR 1952 SC 369 the Apex Court has held that punctuation cannot be allowed to control the plain meaning of a text. It is held as follows:- punctuation is after all a minor element in the construction of a statute, very little attention is paid to English Courts. When a statute is carefully punctuated and there is doubt about its meaning, a weight should undoubtedly be given to the punctuation. Punctuation nay have its uses in some cases, but. it cannot certainly be regarded as a controlling element and can" be allowed to control the plain meaning of a text". ( 15 ) IN the present case, the plain meaning of the text is very clear and the use of Comma neither adds to it nor detracts from its ordinary meaning. In my view, it does not disclose any legislative intention of providing exemption in respect of vehicles kept outside the State of Karnataka for the purpose of' repairs or for body building. ( 16 ) THE Appellate Authority has correctly held that the Petitioners are not entitled for exemption. Them is no merit in these petitions. They are accordingly dismissed. No costs. --- *** --- .