172 Ga. 172 | Ga. | 1931
In 1926 in Macon County, Georgia, an election was held fox the purpose of exempting from taxation certain
In 1923 the General Assembly submitted to tlie qualified voters of the State an amendment to article 7, section 2, paragraph 2, of the constitution of Georgia, providing for the exemption of certain new manufactories or the enlargement of existing manufactories, for a period of five years. This amendment was adopted by the people in the general election of 1924. § 6554(a). In pursuance of this amendment the General Assembly passed the act of 1925, supra, prescribing the regulations under which elections should be held
It is the usual rule of construction that the meaning of each word is to be considered in the light of its associates, as stated in the old Latin maxim judicis est sociis. Plainly, the purpose of the constitutional amendment was to encourage manufácturing in the State. To exempt an infant industry from taxation for a period of five years under the provisions of the act of 1923, ratified by the people in 1924, naturally presented an inducement to the people to go into manufacturing. Also the enlargement of existing manufactories would have the same effect. Considering the meaning of the word “manufacturing” in connection with our consideration of the meaning of processing, it must be plain that the word “processing” has reference only to some stage or process of manufacturing. The generic meaning of the word “cotton” as related to manufacturing, has relation only to cotton as a marketable product in the marts of commerce. The term “cotton” is universally recognized as referring to something which can be manufactured so as to be of use to civilized man. So we are of the opinion the rvord “processing” means a process in manufacturing cotton after it has been put in a marketable form by ginning, which is merely the separation of the cotton from its seed, and .seed-cotton is not referred to in the constitutional amendment. For this reason we think the trial judge correctly refused to enjoin the tax-collector from proceeding to levy and collect the tax fi. fa., issued for the purpose of collecting the taxes upon this ginnery, which had not been exempted from taxation. The only question raised is as to whether the separation of the cotton from its seed is exempted from taxation under the provisions of the act of 1925, supra, which provides for the enforcement of the act-of 1923 adopted by the people in 1924.
Judgment affirmed.