Supreme Court in the
case of Collector of Central Excise Vs Parle Exports Pvt Ltd
reported in 1998 (38) ELT 741 (SC) held that ... under
G.S.T.
15. In Collector of Central Excise Vs Parle Exports Pvt
Ltd1 , the Hon'ble Supreme Court held that it will
purpose for granting
exemption is irrelevant and immaterial.
45. In Parle Exports case (supra), a Bench of two-Judges of this
Court considered the question ... observed as follows :
"... In Collector of Central Excise v. Parle Exports (P) Ltd. ,
(1989) 1 SCC 345, this Court while accepting that exemption
clause
purpose for granting
exemption is irrelevant and immaterial.
45. In Parle Exports case (supra), a Bench of two-Judges of this
Court considered the question ... observed as follows :
"... In Collector of Central Excise v. Parle Exports (P) Ltd. ,
(1989) 1 SCC 345, this Court while accepting that exemption
clause
liberally
[See Collector of Central Excise, BombayI & Anr. vs.
Parle Exports (P) Ltd. , (1989) 1 SCC 345 and Union of
India
Sugandhi Snuff King Pvt. Ltd. & Anr. vs Commissioner (Food Safety) Government ... on 27 September
giving full play bestowing wider and liberal
construction. The ratio of Parle Exports Case (supra) deduced as follows: "Do
not extend or widen
Collector of
Central Excise, Bombay-I & Anr. v. Mis. Parle Exports ... establish his case. Indeed, in the very case of M/s. Parle Exports
(P) Ltd. relied upon by Sri Narasimhamurthy, it was observed:
"While
made. Relying on the decision in Collector of
Central Excise v. Parle Exports (P) Ltd., (1989) 1 SCC 345, it
was held
basis of computerized sheets of sales figures
maintained by M/s. Parle Exports Ltd. whom the figures were sent by the
assessee, the Tribunal
basis of computerized sheets of
sales figures maintained by M/s. Parle Exports Ltd. whom the figures were
sent by the assessee, the Tribunal