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27. As a matter of fact, a two member Bench of the Supreme Court held in CCE vs. Parle Exports Pvt Ltd {1989 (1) SCC 345}, that "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". But the said view was held to be incorrect, by another Bench in State Level Committee vs. Morgardshammar India Ltd {1996 (1) SCC 108}, in view of the decision of the three member Bench in Novopan.

28. Again a three member Bench held in Sarabhai M. Chemicals vs. CCE {2005 (2) SCC 168}, that "it is well settled that an exemption notification has to be strictly construed" and that "the conditions for taking the benefit of the exemption have to be strictly interpreted". Similarly, in Commissioner of Customs -vs- Tullow India Operations Ltd., {(2005) 13 SCC 789} the Apex court held in paragraph 34 as follows:-