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43. Whether the exemption under Section 10(22A) is to be construed strictly or liberally may now be examined. One view is that being an exemption given in a fiscal statute the exemption is to be strictly construed (see Municipal Corporation of Delhi v. Children Book Trust [1992] 3 SCC 390 and Deputy Commissioner of Sales Tax v. Carmel Book Stall [1989] 74 STC 89 (Ker). It is well recognised that the hardship of the assessee is not a factor to be considered in examining whether the exemption is applicable or not. However, it would appear that the present trend is that a liberal interpretation has to be given to such exemption Clauses (see Collector of Central Excise v. Parle Exports (P.) Ltd., AIR 1989 SC 644 (para 17) ; Rohit Pulp and Paper Mills Ltd. v. Collector of Central Excise, AIR 1991 SC 754 para 13 ; CIT v. South Arcot Dist. Co-operative Marketing Society Ltd. [1989] 176 ITR 117 (SC) ; CIT v. Pondicherry Co-operative, Housing Society Ltd. [1991] 188 ITR 671 (Mad); Meenachil Rubber Marketing and Processing Co-operative Society Ltd. v. CIT [1992] 193 ITR 108 (Ker) and CIT v. Gwalior Rayon Silk Mfg. Co. Ltd. [1992] 196 ITR 149 (SC). However, here the controversy is not whether the exemption is to be construed strictly or liberally. What is important is whether the assessee satisfies all the ingredients in Section 10(22A) so as to be entitled to the exemption.