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21. At this stage, it is also pertinent to rely upon the ratio rendered by the Apex Court in the case of Mangalore Chemicals and Fertilisers Limited (supra), on the principles, which govern the construction of an exemption provision. The Apex Court relying upon the precedents on point in the case of Collector of Central Excise versus Parle Exports (P) Ltd, reported in (1989) 1 SCC 345 and in the case of Union of India versus Wood Papers Ltd., reported in (1990) 4 SCC 256 held that 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 or doubt about applicability is lifted and the subject falls in the notification then full play should be given to it and it calls for a wider and liberal construction.

23. Francis Bennion in his Statutory Interpretation, (1984 edn.) says at page 683:

"Unnecessary technicality: Modern courts seeks to cut down technicalities attendant upon a statutory procedure where these cannot be shown to be necessary to the fulfilment of the purposes of the legislation."

24. Shri Narasimhamurthy again relied on certain observations in CCE v. Parle Exports (P) Ltd., 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 Sri Narasimhamurthy, 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."