Barnes, Presiding Judge. The Georgia Department of Revenue, through Robin A. Crittenden, Commissioner, (“the Department”) denied the refunds T-Mobile South LLC (“T-Mobile”) claimed for sales taxes paid on the purchase of certain equipment.[1] T-Mobile’s subsequent petition to the Georgia Tax Tribunal[2] was successful, and the Tribunal ruled that T-Mobile was entitled to the high-technology exemption from sales tax provided by OCGA § 4883 (68) (the “High-Tech exemption”) for its purchases of certain equipment for tax years 2012 through 2016. The Department appealed the decision to the Fulton County Superior Court, which reversed the Tribunal’s ruling. The trial court found that the equipment did not qualify for the High-Tech exemption, and thus T-Mobile was not entitled to the refund. T-Mobile filed an application for discretionary review of the trial court’s judgment, which this Court granted. On appeal, T-Mobile contends that the trial court disregarded and contradicted certain of the Tribunal’s findings of fact, the trial court’s interpretation of the High-Tech exemption conflicted in several regards with the statutory text, the trial court erroneously interpreted the High-Tech exemption to exclude any equipment purchased by wireless communication companies, and the trial court erroneously construed new legislation to retroactively affect the interpretation of the High-Tech exemption.[3] Upon our review, the trial court’s judgment is vacated, and the case is remanded for proceedings not inconsistent with this opinion. Pursuant to OCGA § 5013A17, any party may appeal a final decision of the Tax Tribunal to the Superior Court of Fulton County. The superior court defers to the Tribunal’s factual findings, but may reverse or modify the judgment if substantial rights of the petitioner have been prejudiced because the tribunal judge’s findings, inferences, conclusions, or judgments are: (1) In violation of constitutional or statutory provisions; (2) In excess of the statutory authority of the tribunal; (3) Made upon unlawful procedure; (4) Affected by other error of law; (5) Clearly erroneous in view of the reliable, probative, and substantial evidence on the whole record; or (6) Arbitrary or capricious or characterized by abuse of discretion or clearly unwarranted exercise of discretion. On further appeal to this Court, we conduct a de novo review of claimed errors of law in the superior court’s appellate review of an ALJ’s decision. We also consider de novo any interpretation of a statute or agency. (Citations and punctuation omitted.) Inglett & Stubbs Intl. v. Riley, 339 Ga. App. 375, 376-377 (791 SE2d 642) (2016) (physical precedent only). See OCGA §§ 50-13A-17 (b), (g) . This Court further acknowledges that when reviewing taxation statutes, [t]axation 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 by which it is given will not be enlarged by construction, but, on the contrary, will be strictly construed. 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. (Citations and punctuation omitted.) Ga. Dept. of Rev. v. Owens Corning, 283 Ga. 489, 489-490 (660 SE2d 719) (2008). However, that deference is tempered in that, such “[d]eference is not due unless a court, employing traditional tools of statutory construction, is left with an unresolved ambiguity.” (Citation and punctuation omitted.) City of Guyton v. Barrow, 305 Ga. 799, 803 (2) (828 SE2d 366) (2019). With these standards in mind, we turn to the tax question at issue. Central to this appeal is the tax-exemption status of equipment that T-Mobile purchased to build a high-speed broadband internet network (the “LTE network”). T-Mobile sought over $11 million dollars in sales tax refunds for its LTE network equipment purchased during the calendar years 2012 through 2016.[4] See OCGA § 48-8-1 (noting that there are specific exemptions to the taxing of, among other things, the purchase, use, and sale of property and services). The High-Tech exemption provides for a sales tax exemption on “computer equipment.” The High-Tech exemption provides, in relevant part, as follows: The sales and use taxes levied or imposed by this article shall not apply to: (A) The sale or lease of computer equipment to be incorporated into a facility or facilities in this state to any hightechnology company classified under the [] North American Industrial Classification System ["NAICS"] code [[5]]. . . where such sale of computer equipment for any calendar year exceeds $15 million or, in the event of a lease of such computer equipment, the fair market value of such leased computer equipment for any calendar year exceeds $15 million. . . . (C) (i) As used in this paragraph, the term “computer equipment” means any individual computer or organized assembly of hardware or software, such as a server farm, mainframe or midrange computer, mainframe driven highspeed print and mailing devices, and workstations connected to those devices via high bandwidth connectivity such as a local area network, wide area network, or any other data transport technology which performs one of the following functions: storage or management of production data, hosting of production applications, hosting of application systems development activities, or hosting of applications systems testing. (ii) The term shall not include: (I) Telephone central office equipment or other voice data transport technology. (II) Equipment with imbedded computer hardware or software which is primarily used for training, product testing, or in a manufacturing process.[6] OCGA § § 48-8-3 (68) (A), (C) (2002) (Emphasis supplied.) Thus, the High-Tech exemption is extended to high-technology companies, as identified by NAICS code,[7] who purchase more than $15 million of “computer equipment” for use in Georgia in a given calendar year. See OCGA § 48-8-3 (68) (A). It is undisputed that T-Mobile qualifies as a high-technology company under the NAICS code, and that its purchase of equipment was over $15 million annually. However, the Department denied the tax refund claims upon concluding that T-Mobile had “failed to meet the $15 million purchase requirement of computer equipment as defined by OCGA § 48-8-3 (68).” T-Mobile protested the refund denial, and following a scheduled review conference, the Department again denied the refund. Foremost to the Department’s ruling was its finding that because the “purchased items . . . support [T-Mobile's] mobile telephone network at cell towers and in switching offices[,] [t]he Department considers these items to be ‘telephone central office equipment or other voice data transport technology,’ and thus not computer equipment as defined by OCGA § 48-8-3 (68).” T-Mobile petitioned the Tribunal for an appeal of the Department’s denial. After a four-day evidentiary hearing, at which the Department and T-Mobile introduced expert testimony, the Tribunal reversed the Department’s denial of the sales tax refund. The Tribunal found that the equipment at issue constituted “computer equipment” under OCGA § 48-8-3 (68), rather than “telephone central office equipment or other voice data transport technology,” and thus qualified for the High-Tech Exemption. The Tribunal’s 54-page opinion included over 100 specific and detailed findings of fact, notably: In 2012, T-Mobile began its investment in a new broadband LTE network. The LTE network was launched and available to customers in 2013. The deployment of the new LTE network was a substantial investment which required T-Mobile to purchase computer equipment and software. T-Mobile made this large investment to meet its customers’ demand because the environment was becoming more data-centric. To meet this demand, T-Mobile focused on driving its high-speed data offering. Once launched, the LTE network provided customers high-speed capacity and bandwidth for all data sessions – Internet, smartphones, texting, streaming, social media. A key distinction between the LTE network and prior technology is that LTE is Internet Protocol “IP” based and entirely packet switched. While 3G had some packet switching ability, these networks are still built around circuit switching technology and continue to be capable of circuit switching. Under an entirely LTE system, “you have no voice switches.” A fully packet-switched center is a data center. Although T-Mobile continued to maintain its existing 2G and 3G networks after the launch of LTE, T-Mobile did not continue to make new investments in its existing networks. During the refund claim periods, T-Mobile’s 2G and 3G networks were maintained, but the only equipment that was purchased for these networks was for repairs. LTE is not a voice network– it was “the first wireless system which was designed from the beginning as a data network.” T-Mobile already had 2G and 3G voice networks, and LTE was not intended for voice. When T-Mobile first launched its LTE network in 2013, it was not capable of transmitting voice. Voice could not travel over T-Mobile’s LTE network until June 2014. There was no capability for voice service until that time due to how the software was configured. From that time forward, 98.8 % of the traffic in the LTE network is data, not voice. The “Internet” is an interconnection of devices and systems in order to store, manage, transmit, receive data, and to generate data. “It is a large distributed computer system interconnected with high-speed networks.” The LTE network is one such “distributed network,” and T-Mobile’s network equipment is an integral part of the high-speed Internet. T-Mobile’s LTE network is an assembly of hardware and software that must be interconnected by high-bandwidth connectivity. (Citations omitted.) The Tribunal determined that the terms “computer” and “telephone central office equipment” were not ambiguous, and thus deference to the Department’s interpretation of the terms was unwarranted. Consequently, the Department concluded that “based on the statute’s plain language, . . .each piece of equipment is computer equipment for purposes of the high-tech exemption,” and that the equipment could not be excluded as “telephone central office equipment,” rather than “computer equipment” because “telephone central office equipment” means “equipment used by local exchange carriers to provide wireline service, housed in a central office.” ” The Tribunal noted that it is undisputed that “ T-Mobile does not maintain a telephone central office. “
