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6. Learned counsel for the Revenue submitted that in case of an exemption, the provision has to be construed strictly and onus is on a person who claims exemption to establish that he is entitled to an exemption. There can be no quarrel with the proposition. In fact, in M/s Novopan India Limited Vs. Collector of Central Excise and Customs: , it was observed that the principle that where there is ambiguity of a taxing statute should be constructed in favour of the tax payer does not apply to provision giving a taxpayer relief in certain cases from a section clearly imposing liability. Exemption provisions or exception provisions have to be constructed strictly and onus is on the taxpayer to prove that he is covered by the said provision. In CCE Vs. Parle Exports (P) Limited: