"A 'strict' construction is not to be equated, in this context, with a 20 restricted construction. The court must recognise that it is for a supplier, whose supplies would otherwise be taxable, to establish that it comes within the exemption, so that if the court is left in doubt whether a fair interpretation of the words of the exemption covers the supplies in question, the claim to the exemption must be rejected. But the court is not 25 required to reject a claim which does come within a fair interpretation of the words of the exemption because there is another, more restricted, meaning of the words which would exclude the supplies in question."
"We were intuitively or (sic) the view that item 2(g) does apply to equipment designed solely for the use by a handicapped person regardless of when it became so designed. In our judgement any other reading on (sic) this provision would be unrealistically restrictive. There can be no good reason, 20 either as a matter of statutory construction or common sense, for an item not to be designed solely for use by a handicapped person simply because a factory manufactured item, not so designed, has then been subject to modifications to make it designed for use by handicapped person (sic). In our judgement the statutory saving from VAT made by item 2(g) does not look to the time of 25 design, but to the fact of design. It looks to whether a particular item of equipment is designed, not whether it was historically designed, for use by a handicapped person. It looks to the quality of the item as used by the handicapped person, not the quality of that item when it left the factory."
“In respect of the aircraft that was adapted subsequent to purchase we should say immediately that we accept the evidence to the effect that the only reason why it was not adapted prior to purchase is that, understandably, the vendor did not want the aircraft adapted prior to completion of the contract 5 of sale, for rather obvious reasons. Nonetheless, the evidence satisfies us that it was the appellant's intention at the time when it negotiated the purchase to have the aircraft adapted immediately upon becoming its owner and, in fact, did so. The fact that the adaptations were to take place was, we find as a fact, in the 10 contemplation of all relevant parties at the time of purchase.”
“[Note 4(B)] does not use the expression "establishment" as synonymous with premises or buildings. In that way the legislature has not used the expression "establishment" in what might be considered to be its ordinary meaning, but 25 has preferred to ascribe to it a specific statutory meaning or interpretation.”