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Another principle to be kept in view is what was enunciated by the Supreme Court in Oblum Electrical Industries Pvt. Ltd. v. Collector of Customs, Bombay . It was observed therein that "wordings in the notification have to be construed keeping in view the object and purpose of the exemption". To the same effect is the observation in Collector of Central Excise v. Parle Exports Ltd.

On first impression, it may appear that the above principle goes counter to the observation in Hemraj Gordhandas wherein Their Lordships observed that "the operation of the notification has to be judged not by the object which the rule making authority had in mind but by the words which it has employed to effectuate the legislation intent". However, it is really not so. The object and purpose of the exemption provision is one of the guiding factors to be kept in view in construing the words or expressions of doubtful import or those perceived to be ambiguous or in order to avoid an absurdity or anomaly. At the same time, plain and unambiguous language cannot be ignored by reference to the supposed intention, though in a case where an absurdity would result, the said rule of construction may have to be relaxed.

In Parle Exports case (Supra), the Supreme Court observed:

The expressions in the Schedule and in the notification for exemption should be understood by the language employed therein bearing in mind the context in which the expressions occur. The words used in the provision, imposing taxes or granting exemption should be understood in the same way in which these are understood in ordinary parlance in the area in which the law is in force or by the people who ordinarily deal with them.

Now, we shall deal with the Questions formulated serially: