JUDGMENT V.C. DAGA, J. Heard learned counsel for the rival parties. Perused the statement of case and the question referred for the opinion of this court by the Maharashtra Sales Tax Tribunal, Mumbai, vide its order dated May 3, 2005, which read as under : "Whether, on true and correct interpretation of rule 42-I of the Bombay Sales Tax Rules, 1959, the Tribunal is justified in refusing to grant set-off on purchase tax levied under the Bombay Sales Tax Act, 1959 in respect of purchases of gold which was used in the manufacture of mangalsutra, when the mangalsutra is covered by Schedule entry A30 appended to the Bombay Sales Tax Act, 1959 for the assessment period April 1, 1990 to March 31, 1991, though subsequently referred in rule 42-I with notification dated May 1, 1992 ?" The facts : The statement of facts reveals that the applicant - assessee carried on the business of manufacture and sale of gold and silver ornaments at Sangli. Amongst others, one of the items manufactured was "mangalsutra made of gold", which was sold at a price below Rs. 3,000. No tax was payable on the sale of mangalsutra, since it was covered by entry 30 of Schedule A appended to the Bombay Sales Tax Act, 1959 ("the BST Act" for short). The period of assessment involved herein is from April 1, 1990 to March 31, 1991. Purchase tax under section 13AA became payable with effect from July 1, 1982 at the rate of two per cent on the purchase of goods covered by Schedule C, Part I. Gold was covered by entry 1 of Schedule C, Part I of the BST Act. The Assistant Commissioner of Sales Tax (Assessment), (the assessing officer) passed an assessment order on December 4, 1993 for the period April 1, 1990 to March 31, 1991 and granted set-off under rule 42-I of the Bombay Sales Tax Rules, 1959 ("the BST Rules", for short) and raised demand of Rs. 1,878. Not satisfied with the assessment order, the applicant preferred appeal before the Deputy Commissioner of Sales Tax (Appeals), Pune and challenged the levy of purchase tax under section 13AA and prayed for grant of set-off. The Deputy Commissioner after hearing the applicant dismissed appeal vide his order dated June 26, 1995. 1,878. Not satisfied with the assessment order, the applicant preferred appeal before the Deputy Commissioner of Sales Tax (Appeals), Pune and challenged the levy of purchase tax under section 13AA and prayed for grant of set-off. The Deputy Commissioner after hearing the applicant dismissed appeal vide his order dated June 26, 1995. Again not satisfied by the aforesaid order, the applicant filed second appeal before the Maharashtra Sales Tax Appellate Tribunal at Mumbai ("the Tribunal" for short). During the pendency of the second appeal before the Tribunal, the Deputy Commissioner of Sales Tax (Legal) filed miscellaneous application and prayed for reduction of set-off allowed under rule 42-I of the BST Rules by the assessing officer amounting to Rs. 42,067 holding that set-off was allowable on the sale of mangalsutra though it was not taxable. The applicant objected to the contention seeking reduction of set-off on the ground that rule 42-I contending that set-off was admissible with effect from May 1, 1992 in view of amendment even though sale of mangalsutra, which was exempted since the amendment dated May 1, 1992 did not delete the words "for any period" appearing in rule 42-I. It was, thus, urged that though the assessment was for the period from April 1, 1990 to March 31, 1991 and the amendment was subsequent thereto, i.e., with effect from May 1, 1992, even then the expression appearing in rule 42-I "for any period" will qualify the period under assessment, i.e., 1990-91. After having heard the parties, the Tribunal did not accept the contention of the applicant and allowed the Misc. application filed by the Deputy Commissioner of Sales Tax (Legal) on the ground that mangalsutra was exempted during the year 1990-91. The Tribunal, thus, reduced the set-off by Rs. 42,067 while dismissing the appeal filed by the applicant. Aggrieved by the order passed by the Tribunal in second appeal of the applicant and Misc. application filed by the Deputy Commissioner (Legal), the applicant applied to the Tribunal for reference under section 61(1) of the BST Act. As stated earlier, the Tribunal vide its order dated 3rd May, 2005 referred the question of law to this court for consideration extracted in the opening part of this judgment. Submissions : Mr. application filed by the Deputy Commissioner (Legal), the applicant applied to the Tribunal for reference under section 61(1) of the BST Act. As stated earlier, the Tribunal vide its order dated 3rd May, 2005 referred the question of law to this court for consideration extracted in the opening part of this judgment. Submissions : Mr. Surte, learned counsel for the applicant - assessee, submits that the expression "for any period" will embrace within itself the period of assessment from April 1, 1990 to March 31, 1991, even though rule 42-I is amended with effect from May 1, 1992. He urged that mangalsutra was exempted even before and after the date of amendment made with effect from May 1, 1992. That the notification was issued with a view to exempt mangalsutra from purchase tax under section 13AA of the BST Act, as such refund of tax by way of set-off, paid on gold was rightly allowed by the assessing officer. He, thus, submits that the Tribunal has erred in reducing the set-off. Per contra, Mr. Sonpal, learned "A" Panel counsel appearing for the respondent submits that set-off under rule 42-I of the BST Rules was wrongly granted to the applicant - assessee as the gold used in the manufacture of mangalsutra was purchased and used by the applicant much before the date of amendment. That mangalsutra being tax-free, set-off under rule 42-I was not admissible. That Notification No. STR-1192/CR-49A, Taxation - 1 dated May 1, 1992 itself indicates that all the amendments inserted by this notification were to operate prospectively, i.e., with effect from May 1, 1992. According to him, the words "for any period" in rule 42-I of the BST Rules do not add any relevance to the mangalsutra, which for the first time came on the scene vide notification dated May 1, 1992. Mr. Sonpal submits that the assessment period involved in the present case is 1990-91. That the set-off under rule 42-I is admissible only if the gold is purchased and used in the manufacture of mangalsutra after the date of amendment since the dealer has purchased and used the gold much prior to the amendment, as such the assessee - dealer was not entitled to claim set-off under rule 42-I. Thus, it could not have been granted to the applicant by the assessing officer. The submission is that the notification itself indicates that the Legislature desired to make the inserted rule operative with effect from May 1, 1992. He, therefore, prayed that the question may be answered in favour of the Revenue and against the assessee. Consideration : Having heard rival contentions, the facts stated hereinabove are not in dispute. The entire question revolves around the interpretation of rule 42-I of the BST Rules, which came into force with effect from September 1, 1990. Rule 42-I, prior to its amendment, i.e., at the relevant time, was as under : "42-I. Drawback, set-off, etc., of purchase tax levied under section 13AA. - In assessing the amount of tax payable by a registered dealer (hereinafter in this rule, referred to as 'the claimant dealer'), for any period, the Commissioner shall grant a drawback, set-off, or as the case may be refund of the amount of purchase tax levied under section 13AA on the purchases of goods covered by Part I of Schedule C made by the claimant dealer on or after 1st day of September, 1990, if such goods are, - (i) used by the claimant dealer within the State, - (a) in the manufacture of taxable goods for sale, which manufactured goods have in fact been sold by him; ..." The original Schedule A, entry 30 appended to the BST Act, operative between August 11, 1988 to September 30, 1995 was as under : "30. Mangalsutra with black glass beads sold at a price not exceeding three thousand rupees each." The above rule was subsequently amended vide Government notification dated May 1, 1992 and sub-clause (a) of clause (i) of rule 42-I was substituted as under : "(a) in the manufacture of mangalsutra covered by entry 30 of Schedule A or taxable goods for sale, which manufactured goods have in fact been sold by him;" With the above amendment, the mangalsutra was brought under the above clause, so as to bring it within the scope of rule 42-I of the BST Rules; wherein the words "for any period" were kept intact. The question referred needs consideration in the light of the factual matrix and on the touchstone of rule 42-I of the BST Rules with its application to the assessment year 1990-91 as to whether amended sub-clause (a) of clause (i) of rule 42-I is retrospective so as to cover the assessment period with effect from April 1, 1990 to March 31, 1991. In order to answer the above question, it is necessary to refer to the Government notification dated May 1, 1992, which reads as under : "Notification No. STR-1192/CR-49A/Taxation – 1 dated the May 1, 1992." Whereas the Government of Maharashtra is satisfied that circumstances exist which render it necessary to take immediate action further to amend the Bombay Sales Tax Rules, 1959 and to dispense with the condition of previous publication thereof under sub-section (4) of section 74 of the Bombay Sales Tax Act, 1959 (Bom. LI of 1959) (hereinafter referred to as "the said Act"); Now, therefore, in exercise of the powers conferred by sub-sections (1) and (2) read with the proviso to sub-section (4) of section 74 of the said Act, and of all other powers enabling it in that behalf, the Government of Maharashtra hereby makes the following rules further to amend the Bombay Sales Tax Rules, 1959, namely : "1(1) These rules may be called the Bombay Sales Tax (Amendment) Rules, 1992. (2) They shall come into force on the 1st day of May, 1992. 11. In rule 42-I of the principal rules, in clause (i), in sub-clause (a), after the words 'in the manufacture of', the words, figures and letters 'Mangalsutra' covered by entry 30 of Schedule A of shall be inserted." If one turns to the above notification, it is not in dispute that the object of the Legislature was to amend the rule with a view to add amended sub-clause (a) with effect from May 1, 1992. It is, no doubt, true that sub-clause (a) nowhere says that it has a retrospective effect, but at the same time, while making the amendment, the words "for any period" have not been deleted from rule 42-I of the BST Rules. Now, some meaning will have to be assigned to the words "for any period". It will also be necessary to consider whether it has any relevance to the added sub-clause (a) relating to the mangalsutra. Now, some meaning will have to be assigned to the words "for any period". It will also be necessary to consider whether it has any relevance to the added sub-clause (a) relating to the mangalsutra. At this juncture, it will be useful to make reference to the law laid down by the apex court in the case of J.K. Cotton Spinning and Weaving Mills Co. Ltd. v. State of Uttar Pradesh AIR 1961 SC 1170 ; wherein their Lordships have observed that in the interpretation of statutes the courts should always presume that the Legislature inserted every part thereof for a purpose and the legislative intention is that every part of the statute should be given effect to. The same presumption is also applicable in the case of rules framed under the Act. The construction suggested by Mr. Sonpal, if accepted, the words "for any period" would become surplusage and would be rendered redundant. As ruled by the apex court in the case of Dinesh Chandra Sangma v. State of Assam AIR 1978 SC 17 , no words should be considered redundant or surplusage in interpreting provisions of a statute or a rule. Applying the aforesaid well-settled principle of interpretation, the words "for any period" will bring within itself the period prior to the date of insertion of entry relevant to mangalsutra. The entry relating to mangalsutra was, no doubt, inserted with effect from May 1, 1992 but manufacture thereof and use of gold therein could be prior to the amendment. In order to cover such cases of manufacture, the words "for any period" appear to have been used in the subject rule and were retained even after amendment. Therefore, in our considered view, the gold used in manufacture of mangalsutra prior to the date of amendment will also be entitled for set-off. In the above view of the matter, the question referred is answered in the negative, i.e., in favour of the assessee and against the Revenue.