JUDGMENT K. L. MANJUNATH, J. - Though the matter is listed for admission, by consent, the appeal is taken up for final hearing. This appeal is by the assessee challenging the orders passed by the Additional Commissioner of Commercial Tax, Zone I, Bangalore dated November 8, 2006. The Additional Commissioner of Commercial Tax exercising its powers conferred under section 22A(1) of the Karnataka Sales Tax Act issued a show-cause notice on February 7, 2005 stating that the order passed by the Joint Commissioner of Commercial Tax (Appeals) in the appeal filed by the assessee against the order of reassessment passed by the Deputy Commissioner of Commercial Tax (Assessment) 14, Bangalore has to be revised as the same is illegal, improper and prejudicial to the interest of the Revenue. According to him the assessing authority while concluding the assessment had levied the tax at 12 per cent on the A.C. sheets supplied by the assessee to the taluk panchayat and that the same has been reduced to four per cent by the Joint Commissioner by relying upon the second notification dated February 19, 1999 and such interpretation is contrary to the earlier notification dated March 30, 1996. Since the order passed by the Joint Commissioner of Commercial Tax (Appeals) is prejudicial to the interest of the Revenue, the assessee was called upon to submit his detailed reply. Accordingly, the assessee submitted reply stating that the Government by its notification dated March 30, 1996 had granted concessional rates of tax on the sales made to various Government Departments and also to zilla panchayat. According to the assessee zilla panchayat includes gram panchayat and taluk panchayat. The non-mentioning of taluk panchayat and zilla panchayat is an error committed by the State and that under the subsequent notification dated February 19, 1999 has set right the error committed by it, granted exemption to taluk panchayat as well as gram panchayat. According to the assessee zilla panchayat includes gram panchayat and taluk panchayat. The non-mentioning of taluk panchayat and zilla panchayat is an error committed by the State and that under the subsequent notification dated February 19, 1999 has set right the error committed by it, granted exemption to taluk panchayat as well as gram panchayat. Therefore, it was contended by the assessee that the second notification dated February 19, 1999 is in the nature of clarification and such clarification would relates back to the earlier notification dated March 30, 1996 and it was further contended that the order passed by the Joint Commissioner of Commercial Tax (Appeals) is in accordance with law and the second notification has been properly interpreted by the appellate authority by following the judgment of the Supreme Court in the case of K. P. Varghese v. Income-tax Officer, Ernakulam reported in [1981] 131 ITR 597; AIR 1981 SC 1922 and that the Commissioner of Income-tax, Bangalore v. J. H. Gotla reported in [1985] 156 ITR 323 (SC); AIR 1985 SC 1698 . Therefore, the assessee requested the Additional Commissioner of Commercial Tax to drop this proceeding. The Additional Commissioner of Commercial Tax after considering the reply and on considering the arguments of the assessee came to the conclusion that in view of section 8A of the Karnataka Sales Tax Act, the concession shown to zilla panchayat under the notification dated March 30, 1996 cannot be extended to gram panchayat or the taluk panchayat and the Government in its wisdom in view of section 8A has granted concession to particular class of persons. Therefore, held that the facts of K. P. Varghese case [1981] 131 ITR 597 (SC); AIR 1981 SC 1922 are different from the case of the assessee and allowed the revision and restored the order passed by the assessing authority on December 11, 2000 for the assessment year 1996-97 by setting aside the order passed by the Joint Commissioner of Commercial Tax (Appeals). This order is called in question in this appeal raising the following substantial question of law : "Whether the first respondent is justified in setting aside the order of the second respondent dated October 20, 2004 in rejecting the concessional rate of tax at four per cent on the supply made by the appellant to taluk panchayat in terms of the notification dated March 30, 1996 ?" The learned counsel for the appellant relying upon the judgment in Commissioner of Income-tax, Bangalore v. J. H. Gotla [1985] 156 ITR 323 (SC); AIR 1985 SC 1698 contends that paras 46 and 47 are relevant which read as under : "Where the plain literal interpretation of a statutory provision produces a manifestly unjust result which could never have been intended by the Legislature, the court might modify the language used by the Legislature so as to achieve the intention of the Legislature and produce a rational construction. The task of interpretation of a statutory provision is an attempt to discover the intention of the Legislature from the language used. It is necessary to remember that language is at best an imperfect instrument for the expression of human intention. It is well to remember the warning administered by judge learned Hand that one should not make a fortress out of dictionary but remember that statutes always have some purpose or object to accomplish and sympathetic and imaginative discovery is the surest guide to their meaning. We have noted the object of section 16(3) of the Act which has to be read in conjunction with section 24(2) in this case for the present purpose. If the purpose of a particular provision is easily discernible from the whole scheme of the Act, which in this case is to counteract, the effect of the transfer of assets so far as computation of income of the assessee is concerned, then bearing that purpose in mind, we should find out the intention from the language used by the Legislature and if strict literal construction leads to an absurd result, i.e., a result not intended to be subserved by the object of the legislation found in the manner indicated before, then if other construction is possible apart from strict literal construction then that construction should be preferred to the strict literal construction. Though equity and taxation are often strangers, attempts should be made that these do not remain always so and if a construction results in equity rather than in injustice, then such construction should be preferred to the literal construction. Furthermore, in the instant case, we are dealing with an artificial liability created for counteracting the effect only of attempts by the assessee to reduce tax liability by transfer. It has also been noted how for various purposes the business from which profit is included or loss is set off is treated in various situations as the assessee's income. The scheme of the Act as worked out has been noted before." Zilla panchayats as well as taluk panchayats are created under the provisions of the Karnataka Panchayath Raj Act, 1993 and the gram panchayats, taluk panchayats and zilla panchayats are the creation of the Government and all the three institutions ought to be considered as local bodies created by the Government and therefore, when concessional tax is given to zilla panchayat, it would automatically extended to gram panchayat and taluk panchayat and that a liberal interpretation has to be extended while interpreting the first notification of the year 1996 and similarly relying upon the judgment of the Supreme Court in K. P. Varghese case [1981] 131 ITR 597; AIR 1981 SC 1922 : "... It is now a well-settled rule of construction that where the plain literal interpretation of a statutory provision produces a manifestly absurd and unjust result which could never have been intended by the Legislature, the court may modify the language used by the Legislature or even 'do some violence' to it, so as to achieve the obvious intention of the Legislature and produce a rational construction vide Luke v. Inland Revenue Commissioners [1964] 54 ITR 692; [1963] AC 557. The court may also in such a case read into the statutory provision a condition which, though not expressed, is implicit as constituting the basic assumption underlying the statutory provision. ..." The learned Government advocate relying upon section 8A(1)(b) contends that when an exemption or reduction in rate of any tax has been notified by the Government for the benefit of specified class of persons, the same cannot be extended to other class of persons. ..." The learned Government advocate relying upon section 8A(1)(b) contends that when an exemption or reduction in rate of any tax has been notified by the Government for the benefit of specified class of persons, the same cannot be extended to other class of persons. Relying upon section 8A(2) she further contends that any exemption from tax or reduction notified under sub-section (1) would be subject to such restrictions and conditions as specified in such notification. It would be relevant to quote the provisions of section 8A as under : "Power of State Government to notify exemptions and reductions of tax. - (1) The State Government may, by notification, make an exemption, or reduction in rate, in respect of any tax payable under this Act, - (a) on the sale or purchase of any specified goods or class of goods, at all points in the series of sales by successive dealers; or (b) by any specified class of persons, in regard to the whole or any part of their turnover; or (c) on the sale or purchase of any specified class of goods by any specified class of dealers in regard to the whole part of their turnover. (2) Any exemption from tax or reduction in the rate of tax, notified under sub-section (1) may be subject to such restrictions and conditions as may be specified in the notification. (2A) The State Government may, by notification, transpose any entry or part thereof from one Schedule to another Schedule and alter the point of levy of sale or purchase, but not so as to enhance the rate of tax in any case : Provided that where the point of levy is altered under this sub-section in respect of any goods and if such goods have been subjected to tax under the unaltered entry, then such goods shall not be subjected to tax under the transferred entry. (3) The State Government may, by notification, cancel or vary any notification issued under sub-section (1) or sub-section (2A). (3A) ... ... (3) The State Government may, by notification, cancel or vary any notification issued under sub-section (1) or sub-section (2A). (3A) ... ... (4) If any restriction or condition specified under sub-section (2) is contravened or is not observed by a dealer, the sales or purchases of such dealer may, with effect from the commencement of the year in which such contravention or non-observance took place, be assessed to tax or taxes under the appropriate provisions of this Act as if the provisions of the notification under sub-section (1) did not apply to such sales or purchases. (5)(a) Where any restriction or condition specified under sub-section (2) in respect of goods taxable at the point of sale is contravened or is not observed by the purchaser of such goods, notwithstanding that such a purchaser is not a dealer or that the sale value of such goods is less than the turnover specified in sub-section (5) of section 5, such purchaser shall be liable to pay an amount equal to the difference between the tax payable at the rates specified under the Act and the tax paid at the rates specified under the notification on the goods purchased in respect of which such contravention or non-observance has taken place, as if the provisions of the notification under sub-section (1) did not apply to such purchase and in addition, such purchaser shall also be liable to pay by way of penalty a sum not exceeding the amount equivalent to the amount of tax leviable on the sale price of such goods. (b) The difference of the tax amount and the penalty levied under this sub-section shall be recovered in the manner specified under section 13. (6) Any notification issued under sub-section (1) or sub-section (2A) shall be valid until it is cancelled under sub-section (3), notwithstanding that the tax payable in accordance with such notification in respect of any specified goods or class of goods or by any specified class of persons or on the sale or purchase of any specified class of goods by any specified class of dealers, is modified by an amendment to this Act." From the perusal of section 8A that the Government may extend the benefit of tax either by reducing it or granting concessional rate to any particular class of persons and the same has to be interpreted considering the background of such instructions. In the instant case though taluk panchayats, zilla panchayats or gram panchayat are created under the one Act, in the first notification concessional rate of taxes has been shown to zilla panchayats only. Subsequently, in the year 1999, such benefit is also extended to taluk panchayats and gram panchayats. We have noticed that in the second notification concessional rate of tax granted to taluk panchayats and grama panchayats is with prospective effect and not from retrospective effect. Therefore, if the goods are supplied by the assessee to the taluk panchayat, the assessee cannot rely upon the first notification and at best if any supply is made subsequent to second notification, such concession can be made applicable. Even otherwise we cannot consider assessee as an aggrieved person. If the taluk panchayat has purchased A.C. sheets from the assessee, it is for the taluk panchayat to pay the tax as prescribed under the Sales Tax Act. Therefore, we do not see any merit in this appeal. According to us no substantial question of law arises. In the result the appeal is dismissed.