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"Shri Narasimhamurty again relied on certain observations in CCE v. Parle Exports (P) Ltd., [(1989) 1SCC 345: 1989 SCC (Tax) 84] in support of strict construction of a provision concerning exemptions. there is support of judicial opinion to the view that exemptions from taxation have a tendency to increase the burden on the other unexempted class of tax payers and should be construed against the subject in case of ambiguity. It is an equally well known principle that a person who claims an exemption has to establish his case. Indeed, in the very case of parle Exports (P) Ltd. relied upon by Shri Narasimhamurty, it was observed: (SCC p.357, para 17) `while interpreting an exemption clause, liberal interpretation should be imparted to the language thereof, provided no violence is done to the language employed. It must, however, be borne in mind that absurd results of construction should be avoided.' The choice between a strict and a liberal construction arises only in case of doubt in regard to the intention of the legislature manifest on the statutory language. Indeed, the need to resort to any interpretative process arises only where the meaning is not manifest on the words are plain and clear and directly convey the meaning, there is no need for any interpretation. It appears to us the true rule of construction of a provision as to exemption is the one stated by this Court in Union of India v. Wood Papers Ltd.[(1990) 4 SCC 256 : 1990 SCC (Tax) 422]: (SCC p.260 para 4) `Truly speaking liberal and strict construction of an exemption provision are to be invoked at different stages of interpreting it. When the question is whether a subject falls in the notification or in the exemption clause then it being in nature of exception is to be construed strictly and against the subject but once ambiguity`y or doubt about application then full play should be give to it and it calls for a wider and liberal construction......'"

The learned counsel for the respondent, however, relied upon the decision in Collector of Central Excise. Bombay v. M/s.Parle Exports (P) Ltd. (1989 (1) S.C.R. 345) rendered by a Bench of this Court comprising Sabyasachi Mukharji and S.Ranganathan,JJ. The observations in paras 17 and 18 are particularly relied upon by the learned counsel:

"17. How then should the courts proceed? The expressions in the Schedule and in the notification for exemption should be understood by the language employed therein bearing in mind the context in which the expressions occur. The words used in the Provision, imposing taxes or granting exemption should be understood in the same way in which these are understood in ordinary parlance in the area in which the law is in force or by the people who ordinarily deal with them. It is, however, necessary to bear in mind certain principles. The notification in this case was issued under R.8 of the Central Excise Rules and should be read along with the Act.

We agree with the above statement of law except insofar as it states that where two view of the exemption notification are possible, it should be construed in favour of the subject since it is contrary to the decisions afore- mentioned including the three-Judge Bench decision in Novopan India Limited. It may be noted that this decision was referred to in Mangalore Chemical and Fertilizers and yet a slightly different principle enunciated. So far as decision in Hindustan Alumunium Corporation (referred to in Parle Export), rendered by a Bench comprising Tulzapurkar and R.S.Pathak,JJ., is concerned, it only holds that the expression "mental" occourring in a notification issued under U.P.Sales tax Act should be understood in its primary sense, i.e., in the form in which it is marketable as primary commodity. The learned Judges held that the subsequent forms evolved from the primary from constituted distinct commodities marketable as such and must be regarded as new commercial commodities and not included within the four corners of the notification. This decision cannot therefor be understood as supporting the proposition enunciated in Parle Export with which we have disagreed. Be that as it may, the occasion for appaying the said proposition arises only where there is "real difficulty, in ascertaining the meaning of a particular enactment"

(statement in Parle Exports). In the case before us, there is neither any ambiguity in the language nor does the clause in question present a real difficulty in ascertaining its meaning.
Sri Dhaon, learned counsel for the respondent, then contended that the words "acquired for use in any other factory or workshop in India" must be read and understood as "acquired for use in any other existing factory or workshop in India". The learned counsel says that it should be so read to give effect to the idea underlying the said clause. We are unable to agree. The very definition contained in Explanation (i) uses both the expression "factory or workshop" and "existing factory or workshop" at more than one place which fact would be evident from a bare perusal of the said definition. Wherever the Legislature wanted to refer to an existing factory or workshop, it is not possible to read the words "acquired for use in any other factory or workshop in India" to mean "acquired for use in any other existing factory or workshop in India". We see no reason to add any words to those employed in the clause. It cannot also be said that such addition of word(s)_ is necessary to avoid an absurdity.