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Hansraj Goverdhan v.H.H. Dave, Asstt. Collector, Central Excise & Customs, Surat and Others, [1969] 2 SCR 252 relied on behalf of respondent demonstrates mis-conception about interpreting an exemption provision. It was a case where goods of third persons were manufactured by cooperative society. But once initial hurdle was crossed and it was held that goods had been produced by cooperative society it was found squarely covered in the notification and the Court extended it to goods manufactured by third persons and repelled the submission that object of granting exemption was to encourage formation of cooperative societies and it should be confined to goods manufactured by its members and not others. Similarly in Commissioner of Income Tax v. Madho Prasad, [1989] 4 SCC 541 the provision allowing exemption to 'such part of the income in respect of which the said tax is payable. under the head 'property' as is equal to the amount of rent payable for a year', was construed liberally and it was held that the expression 'equal to the amount of rent payable for a year' did not 'warrant the inference that the benefit of exemption' could 'be claimed only once' because the amount of rent which was sought to be deducted in more than one years was found squarely to fall in Item 36 of notification. It was again a case of interpreting an exemption notification at later stage. Recently in Tata Oil Mills Co. Ltd. v. Collector of Central Excise, [1989] 4 SCC 541, exemption was to soap made from indigenous rice bran oil as against edible oil. The assessee was engaged in manufacture of soap from rice bran fatty acid which was extracted from rice bran oil, in assesses factory. It was found rice bran oil as such could not be used unless it was converted into fatty acid. Therefore the assessee was covered in the notification. Once the ambiguity or about manufacture of soap from rice bran fatty acid was removed the Bench proceeded to construe the word "indigenous" in the notification liberally. In Collector of Central Excise v. Parle Exports (P) Ltd., AIR 1989 644 this Court while accepting that exemption clause should be construed liberally applied rigorous test for determining if expensive items like Gold Spot base or Limca base or Thums Up base were covered in the expression food products and food preparations used in item No. 68 of First Schedule of Central Excise and Salt Act and held 'that it should not be in consonance with spirit and the reason of law to give exemption for non-alchoholic beverage basis under the notification in question.' Rationale or Ratio is same. Do not extend or widen the ambit at stage of applicability. But once that hurdle is crossed construe it liberally. Since the respondent did not fall in the first clause of the notification there was no question of giving the clause a liberal construction and hold that production of goods by respondent mentioned in the notification were entitled to benefit.