1. Article 7, section 7, paragraph 1, of the constitution (Code, § 2-5501), inhibits a political division of the State (except аs in the constitution provided for) from incurring a debt exceeding “seven per centum of the assessed value of all the taxable property therein.”
2. “It is a . . rule in the construction of grants of exemptions from taxation, whether such grants be by statute or the constitution, that such exemptions should be strictly construed in favor of the public, and that nothing рasses by implication; but this rule must not be pushed to unreasonableness.” City of Columbus v. Muscogee Mfg. Co., 165 Ga. 259 (
3. “Taxation is the rule; exemption from taxatiоn is the exception. The grant of an exemption from taxation rests upon the theory that such exemption will bеnefit the body of the people, and not upon the idea of lessening the burdens of the individual owners of property.” City of Columbus v. Muscogee Mfg. Co., supra; Mayor and Council of Gainesville v. Brenau College, 150 Ga. 156 (2) (
4. “ There is hereby exempted of owners, beginning January 1, 1938, from all ad valorem taxation, state, county, municipal, and school district, all clothing, household, and kitchen furniture and all other personal property, except as hereafter excepted, not to exceed $300 in actual value. Provided, the person or persons herein entitled to exemption shall register such exemption of
5. “Beginning January 1, 1938, there shall be exempted from all ad valorem taxation for state, county, and school purposes the homestead оf each resident of this State actually occupied by the owner as a residence and homestead, to the value of $2,000, and only so long as actually occupied by the owner primarily as such, with the exception оf taxation to pay interest on and retire bonded indebtedness. Such value to be determined in such manner and according to such rules and regulations as may be prescribed by law. That the General Assembly may from time to time, as the
(a) This exemption from taxation for “school purposes” should not be construed to include exemptiоn for purpose of building a schoolhouse. Seaboard Air-Line Railway Co. v. Wright, 165 Ga. 367, 371 (140 S. E. 863 ); Stapleton v. Martin, 164 Ga. 336 (5) (138 S. E. 767 ).
(b) It would seem that if the language “school purposes” did contemplate building a schoolhouse, it should be ruled that the words “with the exception of taxation to pay interest on and retire bonded indebtedness,” considered with the context, should be construed as creating an exception from the declared exemption оn the basis of the purpose of taxation, and that when the purpose of the taxation was “to pay interest on and retire bonded indebtedness,” the realty referred to will not be exempt from taxation for that purposе.
6. The Red Bud Consolidated School District in Gordon County is a political division of the State of Georgia. Ty Ty Consolidated School District v. Colquitt Lumber Co., 153 Ga. 426 (
7. On the question whеther the assessed value of all taxable property in the Red Bud Consolidated School District was such that a proposed bonded indebtedness of $15,000 to build a schoolhouse, would exceed “seven per centum” of such аssessed value, the value of exempted personalty should be omitted, while the value of exempted realty should be counted. Where, as in the instant case, the assessed values of the realty alone are such that thе proposed debt would not exceed seven per centum of property values, omitting from the count thе assessed value of exempted personalty, the school district would be authorized to incur the bonded indebtedness.
8. On application of the foregoing principles, the judge did not err in dismissing the intervention and validating the bonds.
Judgment affirmed.