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35. In the judgment of two learned Judges in Union of India v. Wood Papers Limited, (1990) 4 SCC 256 [hereinafter referred as 'Wood Papers Ltd. Case' for brevity], a distinction between stage of finding out the eligibility to seek exemption and stage of applying the nature of exemption was made. Relying on the decision in Collector of Central Excise vs. Parle Exports (P) Ltd., (1989) 1 SCC 345, it was held "Do not extend or widen the ambit at the stage of applicability. But once that hurdle is crossed, construe it liberally". The