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16. Learned Counsel for the petitioner further relied upon a judgment of the honourable Supreme Court in the case of Parle Biscuits (P) Ltd. v. State of Bihar , wherein the honourable Supreme Court placed reliance on an earlier judgment of the Supreme Court in the case of Hansraj Gordhandas v. H.H. Dave Assistant Collector of Central Excise and Customs . In that case the honourable apex court came to hold as follows (para 5 of AIR):

...It was contended on behalf of the respondent that the object of granting exemption was to encourage the formation of co-operative societies which not only produced cotton fabrics but which also consisted of members, not only owning but having actually operated not more than four power looms during the three years immediately, preceding their having joined the society. The policy was that instead of each such member operating his looms on his own, he should combine with others by forming a society which, through the cooperative effort should produce cloth. The intention was that the goods produced for which exemption could be claimed must be goods produced on its own behalf by the society. We are unable to accept the contention put forward on behalf of the respondents as correct. On a true construction of the language of the notifications dated July 31,1959 and April 30,1960 it is clear that all that is required for claiming exemption is that the cotton fabrics must be produced on power-looms owned by the co-operative society. There is no further requirement under the two notifications that the cotton fabrics must be produced by the co-operative society on the power looms for itself. It is well-established that in a taxing statute there is no room for any intendment but regard must be had to the clear meaning of the words. The entire matter is governed wholly by the language of the notification. If the tax-payer is within the plain terms of the exemption it cannot be denied its benefit by calling in aid any supposed intention of the exempting authority. If such intention can be gathered from the construction of the words of the notification or by necessary implication therefrom, the matter is different but that is not the case here. Their Lordships refer to the observations of Lord Watson in Salomon v. Salomon and Co. 1897 AC 22 at page 38: