We granted certiorari in this case to determine whether the Court of Appeals erred by holding that the 1997 version of OCGA § 48-8-3 34 A clearly and unambiguously creates an exemption from taxation for machinery repair parts. See Owens Corning v. Ga. Dept. of Revenue , 285 Ga. App. 158 645 SE2d 644 2007. Based on the applicable standards of review, the legislative history of the statute, and the Legislature’s expressed intent that machinery repair parts not be extended a sales tax exemption prior to 2000, we find that no clear, unambiguous exemption for machinery repair parts existed in 1997. Therefore, we must reverse. Based on its contention that the 1997 version of OCGA § 48-8-3 34 A provided a sales tax exemption for machinery repair parts for machinery it used directly for the manufacture in Georgia of tangible personal property for sale, Owens Corning filed a claim with the Georgia Department of Revenue seeking a refund for sales taxes it paid on such parts between July 1, 1997 and December 31, 1999. The Department failed to rule on this claim, and, as a result, Owens Corning brought an action seeking a refund pursuant to OCGA § 48-2-35. Thereafter, Owens Corning and the Department filed cross-motions for summary judgment, and the trial court granted the Department’s motion and denied Owen Corning’s motion.1 On appeal, the Court of Appeals reversed,2 and we granted certiorari.
The standards for reviewing taxation statutes are well-settled. Taxation is the rule, and exemption from taxation is the exception. And exemptions are made, not to favor the individual owners of property, but in the advancement of the interests of the whole people. Exemption, being the exception to the general rule, is not favored; but every exemption, to be valid, must be expressed in clear and unambiguous terms, and, when found to exist, the enactment which it is given will not be enlarged by construction, but, on the contrary, will be strictly construed.Citations and punctuation omitted. Collins v. City of Dalton , 261 Ga. 584, 585-586 4 a 408 SE2d 106 1991. Moreover, the interpretation of a statute by an administrative agency which has the duty of enforcing or administering it is to be given great weight and deference. See, e.g., Kelly v. Lloyd’s of London , 255 Ga. 291, 293 336 SE2d 772 1985.
