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In a later decision in the case of Collector of Central Excise, Bombay v. Parle Exports (P) Ltd., reported in 1988 (38) E.L.T. 741 (S.C) = (1989) 1 SCC 345, the Apex Court held :-

"The expression 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. According to the tradition of our law, primacy is to be given to the text in which the intention of the law giver has been expressed. 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. When a notification is issued in accordance with power conferred by the statute, it has statutory force and validity and, therefore, the exemption under the notification is, as if it were contained in the statute itself. The notification has to be read as a whole in the context of other relevant provisions in the statute. When two views of a notification are possible, it should be construed in favour of the subject as notification is part of a fiscal enactment. Though in a taxing Act provision enacting an exception to the general rule of taxation has to be construed strictly against those who invoke its benefit, but While interpreting an exemption clause, liberal interpretation should be imparted to the language thereof, provided no violence is done to the language employed. It is only, however, in the event of there being a real difficulty in ascertaining the meaning of a particular enactment that the question of strictness or of liberality of construction arises. However, absurd results of construction should be avoided."